27th April 2026

U.S. IEEPA Tariff Refund Process – Now Live

The U.S. tariff refund process relating to duties collected under the International Emergency Economic Powers Act (IEEPA) has now materially progressed.

Effective 20^th April 2026, U.S. Customs and Border Protection (CBP) has launched Phase 1 of its refund mechanism through the Automated Commercial Environment (ACE) using the new Consolidated Administration and Processing of Entries (CAPE) system. This represents the first operational pathway for refunds to be processed.

Please be advised that Phase 1 will only cover refund requests for IEEPA entries finalised by CBP within the last 80 days, from January 30th – April 19th, 2026.

What this means for you

Refunds are now being actively administered by CBP for eligible Phase 1 entries, subject to CBP’s validation and review processes.
While this is a significant step forward, eligibility and responsibility for reclaiming duties depends on entry status, incoterms, and the carrier used.

Please note:

Refunds are processed solely by CBP
No changes can be made by ILG or importers to entries once filed
Processing timelines remain controlled by CBP and are currently expected to be
approximately 60–90 days from acceptance of a valid Phase 1 claim

How refunds are reclaimed – carrier and incoterm position

We appreciate that the most common question we are currently receiving is “who reclaims the refund?”. Based on our discussions with carriers and current confirmed processes, the position is as follows for both DDP and DDU shipments, by carrier.

DDP shipments:

The following guidance is for shipments moved using DDP incoterms and were subject to IPEEA duty.

Express Carriers: FedEx / UPS / DHL Express:
- Where shipments moved DDP via an express carrier and the carrier acted as Importer of Record, the carrier will process the refund on behalf of customers.
- This approach has been confirmed by FedEx and UPS.
- Once ILG receives the refunded duties from the carrier, a credit note will be raised to the ILG customer.
- At the time of writing, confirmation from DHL Express is still pending; however, we expect DHL to follow a similar process
- Importantly, where the express carrier acted as Importer of Record, no action is required from customers, and there is no need to contact ILG. Refunds can only be issued once the carrier has received the funds from CBP.
Hybrid / Economy Carriers: Starlinks / DPD Local / Landmark:
- Where shipments moved DDP via a hybrid or economy carrier and the ILG customer is the Importer of Record, it will be the customer’s responsibility to reclaim the duties directly through the CBP process.
- If you fall into this category, your Corporate Account Manager should already have shared detailed, carrier‑specific guidance. If you have not received this, or if your routing differs from the above, please contact them directly.

DDU Shipments:

For DDU shipments, the importer of record is typically the recipient, and it will be their responsibility to pursue any refund directly, regardless of carrier.

What has not changed:

The existing 10% baseline tariff, imposed under separate authority, remains in force and is not refundable.
The U.S. Government retains the right to appeal elements of the Court of International Trade’s orders, although CBP has proceeded with Phase 1 implementation.
Any customs, carrier accessorial, administration, arrangement, or deferment charges are not refundable.

Further information and next steps:

For shipments where refunds will be passed on via ILG credit notes, these will only be issued once the funds have been received from the carriers.
Any statutory interest applicable to refunded duties is calculated and paid by U.S. Customs and Border Protection to the Importer of Record and, where relevant, will only be passed on once received.
There is currently no published guidance for refund phases beyond Phase 1 however the CBP has confirmed that exclusion from Phase 1 does not remove entitlement to refunds, which are expected to be addressed in subsequent phases.
Where a carrier is acting as Importer of Record and reclaiming duties on your behalf, customers should not attempt to submit parallel claims directly to CBP, as this may delay processing.

Support:

To support our clients through this process, we have established a dedicated mailbox for IEEPA refund‑related queries – IEEPADutyReclaims@ilguk.com

Therefore if you:
- Have questions about your specific routing
- Believe you used a carrier not referenced above
- Need help understanding importer‑of‑record responsibilities
Or have any questions, please do not hesitate to contact us via this email address where your query will be logged in our ticketing system and responded to accordingly.

Further Information:

For customers who wish to reference official carrier and U.S. Customs guidance directly, the following external resources provide further detail on the IEEPA tariff refund process:

Please note that these sites are maintained by third parties and U.S. authorities. ILG provides these links for reference only and cannot control the content, timing, or interpretation of updates published externally.

We will continue to monitor CBP activity, carrier communications, and future phases of the refund process, and we will issue further updates as verified information becomes available.

Should you have any questions please contact your corporate account manager or IPEEADutyReclaims@ilguk.com.

< Back to Updates