24th July 2026
U.S. IEEPA Tariff Refund Process Update | 24.7.26
Refund Process Now Active
CBP is now actively accepting and processing refund requests under a phased implementation of its Consolidated Administration and Processing of Entries (CAPE) system.
Under CBP’s current Phase One approach, refund requests are being accepted for certain unliquidated entries and certain entries liquidated within 80 days, meaning only certain tariff payments made from 30 January 2026 onwards, together with qualifying pending entries, are currently eligible for processing.
We are pleased to confirm that we have now started to see the first refunds being processed and returned through certain carrier channels. While volumes remain low at this stage and refunds are arriving gradually, this demonstrates that the CBP and carrier refund mechanisms are now operating.
Which Tariffs Are Eligible For Refund?
Refunds only apply to tariffs imposed under the International Emergency Economic Powers Act (IEEPA) that were subsequently invalidated by the U.S. Supreme Court.
The following remain unaffected and are not refundable under this programme:
- Section 122 tariffs
- Section 232 tariffs
- Section 301 tariffs
- The existing 10% baseline tariff
- Any other duties, taxes or government charges not covered by the IEEPA ruling
Refunds Will Be Processed In Multiple Phases
CBP has confirmed that refunds will be administered in multiple phases.
Phase One only applies to specific categories of entries and liquidation periods. As a result, customers who ultimately may be entitled to a refund may not yet fall within the current processing phase.
Customers should therefore not assume that the absence of a refund at this stage means that a refund is unavailable. It may simply mean that the relevant entry has not yet been processed by CBP or included within the current phase.
Processing Timelines Remain Unclear
Whilst refunds are now starting to be issued, there is currently no published or reliable timeline for how quickly individual claims will be reviewed, approved and paid.
Processing times remain entirely under the control of CBP and the relevant carriers.
Individual entries are being reviewed separately, and refund timing may vary significantly between importers, carriers and shipment types.
The fact that another shipment, importer or business has received a refund does not indicate that a separate entry has been approved, rejected or processed, as each entry is reviewed independently.
Clarification Of ILG’s Role
Given the number of enquiries being received, we would like to clearly explain ILG’s role within this process.
ILG is not responsible for:
- Determining eligibility for refunds
- Submitting claims to CBP
- Reviewing or approving claims
- Calculating refund values
- Interpreting CBP decisions
- Providing legal, customs, tax or duty recovery advice
- Influencing or accelerating CBP processing
- Influencing or accelerating carrier refund activity
Our role is limited to receiving refunded duty amounts where applicable and passing those refunds on to customers. Accordingly, ILG is unable to provide guidance, predictions, insight or assurances regarding the outcome, value or timing of individual refund claims.
Credit Notes
Where refunds are received by ILG from carriers, we will process and issue corresponding credit notes to customers. ILG will only pass on credits once funds have actually been received. Credit notes cannot be issued based on expected refunds, pending claims or estimated entitlement.
To ensure consistency and accuracy, all refund credits received will be processed through a monthly credit note cycle.
Refund credits may be received and processed over an extended period and should not be expected to arrive as a single consolidated payment.
Administration Fees
We have received a number of questions regarding administration fees previously charged in connection with IEEPA duties.
These fees related to the assessment, rating and administration of IEEPA tariffs at the time of importation. These services were performed when the tariffs were lawful, valid and payable, and therefore those fees remain non-refundable. However, ILG will not apply any administration fee for processing or posting refund credit notes received through this programme.
What You Should Do Now
At this stage, customers are not required to take any action unless they are the Importer of Record and are responsible for pursuing refunds directly through the applicable CBP process.
For customers where a carrier is acting as Importer of Record and reclaiming duties on their behalf, no action is required. Refunds and credit notes will be processed if and when funds are received.
Continuing Developments
We continue to actively monitor:
- Further CBP guidance regarding future refund phases
- Carrier-specific refund processes and timelines
- Additional operational guidance from CBP
- Any developments that may affect refund administration
Customers wishing to review the latest official guidance may refer to CBP and carrier-specific publications directly, however customers should note that ILG cannot interpret, validate or provide advice on external guidance or the application of that guidance to individual refund claims.
As always, we will continue to communicate verified information as it becomes available. We will update you via email and also via our customer hub.
Due to the volume of entries being assessed by CBP and carriers, we are unable to provide shipment-by-shipment progress updates for claims that remain under review.
We kindly ask customers not to request status updates on pending claims, as neither ILG nor its carrier partners are currently able to provide reliable estimated payment date.
Should you have any questions regarding shipment routing, importer of record responsibilities or the status of credits already received by ILG, please contact our dedicated mailbox at IEEPADutyReclaims@ilguk.com.