16th March 2026
Update on U.S. IEEPA Tariff Refund Process
Read below for an update on the developing situation in the United States regarding refunds of tariffs previously imposed under the International Emergency Economic Powers Act (IEEPA).
Latest Developments
- The U.S. Court of International Trade (CIT) has confirmed that U.S. Customs and Border Protection (CBP) is making satisfactory progress toward establishing the mechanism to process refunds of the unlawfully collected IEEPA duties. As part of this work, CBP is building new functionality within its Automated Commercial Environment (ACE), referred to as the Consolidated Administration and Processing of Entries (CAPE) system, with an online claims portal reported as approximately 70% complete.
- The CIT has required CBP to provide another progress report to the court by 19th March 2026, underscoring that the legal and operational environment remains fluid and closely supervised.
Current Position and Remaining Uncertainty
- Despite these steps forward, no formal timeline or procedural guidance has yet been published by CBP on how refunds will be administered. The scale of required review remains unprecedented, and both operational sequencing and prioritisation are still under development. Your previous responsibilities remain unchanged: all liquidations and reliquidations will be executed solely by CBP, and importers cannot amend their own entries.
- Additionally, the U.S. Government retains the right to appeal the CIT’s orders and is widely expected to do so within the statutory timeframe. This may affect the ultimate scope or timing of refunds issued.
- It is important to note that the existing 10% baseline tariff which is separate from the IEEPA measures remains in force and should continue to be included in any landed cost calculations.
Our Commitment to You
We fully understand the urgency and importance of this matter for our clients, especially where significant duty values are involved. The situation continues to evolve, and we are actively monitoring all developments from CBP, the CIT, and U.S. government agencies.
We will keep you regularly updated as soon as new, verified information becomes available.
If you have any questions or wish to discuss how this may affect your shipments, please reach out to your usual ILG contact.