In a declaration presented to the Court of International Trade (CIT) on March 6, 2026, Customs and Border Protection announced its consideration of a system to issue refunds for imports affected by tariffs under the International Economic Powers Act (IEEPA), and offered assurances that it could be implemented within the next 45 days.

In a previous decision by the CIT, Customs and Border Protection (CBP) was ordered to refund all IEEPA tariffs on all entries not fully liquidated, a challenge that was largely borne on the scale of the number of entries that would require case-by-case reviews - the current process through which Customs and Border Protection (CBP) handles protests and post summary corrections. 

The process, as proposed, would involve the following in the Automated Commercial Environment (ACE) filing system:

1. The importer files a declaration in ACE that lists the entries on which IEEPA duties were paid. 
2. ACE then validates each entry within the declaration and automatically recalculates the duty owed without IEEPA. 
3. CBP verifies the declaration and begins the next phase of the refund process.
4. With that verification, ACE then automatically begins finalizing the entries. 
5. It aggregates the refund with interest according to the importer and the liquidation date. 
6. CBP certifies the results. 
7. A refund is then issued via the Department of the Treasury electronically.

In a statement, Brandon Lord, Executive Director for the CBP Office of Trade, stated that he was “confident” that the CBP could develop and implement this new ACE functionality in the next 45 days. 

For importers, this declaration means the following: 

1. Hearings for the cases relevant to this refund are currently ongoing, and both the above proposal and the rulings in general could easily be overturned. This is not a finalized system, but a possible one.
2. If you are not already in the ACE portal and registered for the CBP Automated Clearing House (ACH), then now is the time to do so. Whatever form this refund system takes, it will likely involve these two systems. 

To read the complete filing, click here. 

This story is ongoing, and we will continue to monitor it as it evolves.

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