As of April 20, importers can begin submitting refund claims through U.S. Customs and Border Protection’s new tariff refund system. For importers that paid tariffs under the International Emergency Economic Powers Act (IEEPA), this represents a potentially significant cash recovery, provided documentation, data, and internal coordination are in order.
Below, we outline what importers should know about navigating the tariff refund system, including filing steps and key financial and operational considerations.
Timeline of the Tariff Refund System
CBP developed the Consolidated Administration and Processing of Entries (CAPE) system to remove, recalculate, and refund IEEPA duties at scale. CAPE operates within the Automated Commercial Environment (ACE), the platform importers already use to file entry summaries and report duty payments.
Grassi has been monitoring this rollout closely through a series of recent updates:
- February 20, 2026: The Supreme Court ruled that the use of IEEPA to impose sweeping global tariffs was unlawful.
- March 6, 2026: In a filing with the Court of International Trade, CBP outlined a plan to build a centralized solution within ACE in approximately 45 days.
- March 12, 2026: CBP then detailed a four-step process covering claim submission, recalculation, liquidation or reliquidation review, and refund issuance.
- March 30, 2026: CBP further defined Phase 1 eligibility, confirming which entries will be accepted first and deferring categories such as reconciliation and drawback entries to later phases.
- April 20, 2026: Phase 1 of CAPE was launched at 8:00 a.m. ET, allowing importers of record and authorized customs brokers to begin filing refund claims.
For details on how CAPE functions and Phase 1 filing requirements, refer to CBP’s IEEPA Duty Refunds page.
Step-by-Step Guidance: What Importers Should Do Now
Importers are now responsible for initiating the refund process and ensuring systems and records are prepared to receive payment. To prepare, consider the following steps:
Step 1: Confirm ACE Portal and ACH setup
CBP issues refunds electronically via ACH. Refund banking details must be on file in ACE separately from banking used for duty payments, and CBP will hold refunds until that setup is complete.
For more step-by-step guidance on enrollment and portal access, review the following resources:
- ACH refund reference page
- Electronic refund enrollment training video
- ACE Portal application instructions
Step 2: Identify Eligible Entries Before Filing
CAPE Declarations are submitted as CSV files listing entry numbers only, with a limit of 9,999 entries per submission. Accepted declarations cannot be amended, and missed entries require a separate filing.
Before filing, importers should confirm each entry:
- Exists in ACE
- Includes at least one IEEPA Chapter 99 tariff line
- Meets Phase 1 eligibility, including the 80-day liquidation timing window
Step 3: Submit Refund Claims through CAPE
IEEPA refund claims must be submitted through CAPE. CBP does not permit initiating these requests through Post Summary Corrections. Only the importer of record or the broker that filed the original entry may submit a declaration.
Brokers may submit on behalf of importers, but responsibility for accuracy remains with the importer of record.
When Will Importers Receive Tariff Refunds?
CBP expects valid refunds to be issued within 60 to 90 days after a CAPE Declaration is accepted. Refunds will not be issued until entries are fully processed, and CBP may apply amounts against outstanding obligations before releasing any remaining balance.
What Tariff Refunds Could Mean for Accounting, Finance, and Operations
These refunds are not just a one-time cash recovery event. The impacts may ripple across inventory, margins, financial reporting, and how recoveries are handled across the supply chain.
Businesses should assess the impact across the following areas:
- Inventory valuation: If IEEPA duties were capitalized into inventory, refunds may require revisiting carrying values and reassessing margins on goods already sold or still on hand.
- Cost of goods sold: If duties were expensed, refunds could affect gross margins and current-period comparability. The accounting treatment depends on when the original cost was recognized and when the refund is recorded.
- Cash flow timing: Companies should avoid assuming near-term inflows until a CAPE Declaration has been accepted and processing timing becomes clearer.
- Financial statement disclosure: Refunds related to prior-period duties may require separate presentation or disclosure, especially where amounts are material or span multiple reporting periods.
- Commercial and contractual obligations: Importers of record should review pricing agreements, supply contracts, and intercompany arrangements before assuming recovered duties are theirs to retain.
How Grassi Can Help
Grassi is here to support businesses operating across global supply chains as they navigate the financial, operational, and strategic implications of tariff refunds and broader trade policy shifts. We help organizations understand how recoveries may affect inventory, margins, financial reporting, and cash flow, and how to incorporate those impacts into broader planning and decision-making.
For more information on how the tariff refund process may affect your business, contact a Grassi advisor.
