US Customs’ IEEPA Tariff Refund Process
As reported in the April edition of Route, US Customs and Border Protection (CBP) has launched its new Consolidated Administration and Processing of Entries (CAPE) system, which is the dedicated platform for processing International Emergency Economic Powers Act (IEEPA) tariff refunds. IEEPA Tariffs were struck down by the US Supreme Court earlier this year.
Importers who are not self-filing their claims should contact their customs broker as soon as possible to get the process started and ensure they receive all refunds due. Note – any duties issued due to Section 232 (Steel, Aluminum, Copper, etc.) or Section 301 (China Tariff) are not subject to refunds. Refunds are limited to the IEEPA Tariff (also known as the Reciprocal Tariff) portion of duties paid.
CAPE is being released in phases, with components made available to the public as they are completed:
CAPE Phase I
In CAPE Phase I, CBP will process IEEPA tariff refunds only for unliquidated entries and liquidated entries for which CBP’s 90-day voluntary reliquidation period has not expired. Upon completion of processing, CBP will issue a refund, including interest (currently at a rate of 7% per annum), within an estimated 60-90 day processing time.Importers and their brokers can upload a CSV file listing the entries for which IEEPA refunds are requested. The CAPE system will then validate the CSV file against the Automated Commercial Environment (ACE) and the relevant entry data to calculate the refund as the IEEPA duty paid, less the applicable Chapter 1–97 duty that would otherwise be owed.
Future CAPE Phases
CBP has not yet identified how it will process IEEPA tariff refunds for entries that do not fall within the parameters of CAPE Phase I (e.g. entries covered by an open protest, flagged for reconciliation, subject to a drawback claim, and those entries for which liquidation is final)
More information will be provided as it becomes available
To be eligible to use CAPE, the following prerequisites apply:
- The Importer of Record (IOR) or an authorized customs broker must have an established ACE Portal account.
- Refund recipients must use the ACE Portal account to provide CBP with bank account information for refunds.
- Refunds will be paid electronically by Automated Clearing House (ACH), and recipients must have a U.S. bank account information designated for refunds on file with CBP.
- If you do not have a US bank, Universal can act as your “Notify Party” – refunds will be directed to Universal and forwarded to you. If you cannot designate Universal as the Notify Party through the ACE portal, you can submit CBP Form 4811 in lieu of filing through the portal – Universal will file the 4811 with CBP on your behalf.
For more information or to have Universal Logistics file your IEEPA Tariff Refund requests, contact Brian Rowe, Director – Customs Consulting and Regulatory Affairs.
US Customs Consulting Services
In an increasingly complex US trade environment shaped by evolving tariffs, IEEPA refund processes, CUSMA/USMCA compliance requirements, and heightened CBP enforcement, US importers need more than a customs broker – they need a trusted advisor.
Universal Logistics USA’s US Customs Consulting Services team, based at our Buffalo, NY office, provides the regulatory expertise and trade advisory support that today’s importers depend on to keep their shipments moving, their compliance intact, and their duty exposure properly managed.
From product classification under the Harmonized Tariff Schedule and valuation guidance, to USMCA/CUSMA origin eligibility, binding rulings, post-entry services, duty drawbacks, and consultation on anti-dumping and countervailing duties, our US Customs Consulting Services team helps clients navigate the full spectrum of US customs compliance with confidence.
This dedicated team is jointly led by Cody Keser, Consultant – Regulatory Compliance, and Matthew Williamson, Consultant – Trade Advisory. Together, Cody and Matthew bring the credentials, hands-on experience, and client-first approach that define Universal Logistics USA’s commitment to premium client care.
Understand How Your Cargo Is Being Shipped:
Incoterms and How They Affect Liability
When goods move across borders, one of the most important — and most frequently misunderstood — elements of the transaction is the Incoterm. Getting it right protects your business. Getting it wrong can mean unexpected costs, compliance penalties, transit delays, and disputes that strain relationships with your trading partners.
What Incoterms Actually Do
Incoterms (International Commercial Terms) are standardized trade rules, published by the International Chamber of Commerce (ICC). They define the responsibilities, costs, and risks of buyers and sellers in international shipping, providing a clear framework for:
- When risk transfers from the seller to the buyer
- Who is responsible for arranging and paying for transportation
- Who is responsible for insuring the goods in transit
- Who handles export and import customs clearance
It is important to note that Incoterms do not determine ownership of the goods. What they do – clearly and unambiguously – is establish when control, possession, and liability (risk) shift from one party to the other. That distinction is critical to determining who must insure the cargo for each leg of the journey.
The Common Misconception
The most common misconception about Incoterms is that they simply define who pays for what. While that is part of the picture, Incoterms also spell out the responsibilities of both the shipper and the consignee, and these obligations are frequently overlooked.
Misinterpreting your responsibilities under a given Incoterm can lead to:
- Increased costs from unexpected charges, storage, or demurrage
- Non-compliance penalties issued by federal authorities
- Delays in transit times caused by unclear handoffs at origin or destination
- Disputes between buyer and seller over who should have insured, cleared, or paid for a specific portion of the move
Based on our historical review of these issues, a lack of familiarity with Incoterm use — and a lack of awareness of one’s own responsibilities under the applicable terms — is among the most common and most avoidable problems we see in international trade.
Why It Matters for Insurance and Liability
Cargo insurance and Incoterms are closely linked. Each term establishes a precise point at which risk transfers between seller and buyer. If neither party arranges insurance for the portion of the journey for which they are responsible, the cargo may be uninsured when something goes wrong, and the financial loss falls on whoever holds the risk at that point.
For example, under terms such as CFR or FOB, the seller arranges the main carriage, but the buyer assumes risk once the goods are on board the vessel. Under CIF or CIP, the seller is required to arrange insurance on the buyer’s behalf. Under DDP, the seller carries risk and cost almost all the way to the buyer’s door. Each scenario has very different implications for who needs to act, when, and how.
How Universal Logistics Can Help
Universal Logistics works with importers and exporters every day to ensure the right Incoterm is selected for each transaction – one that fits the mode of transport, reflects the commercial agreement, and aligns insurance coverage with the actual transfer of risk. Our team can review your existing terms of sale, identify exposure in your current arrangements, and recommend adjustments that reduce cost and risk.
For a full breakdown of the 11 Incoterms, including a side-by-side cost-responsibility chart and complete definitions, visit the Incoterms reference page on our website.
For more information, contact Debbie McGuire, Director – Freight Solutions.
Airfreight Update
The International Air Transport Association (IATA) has released its March data for global air cargo markets, showing a 4.8% decline in cargo demand compared to the previous year. IATA attributed the decline primarily to severe disruptions at major Gulf hubs due to the ongoing conflict in the Middle East.
Rates spiked, then began to stabilize
International airfreight rates increased substantially between March and April, driven by:
- Reduced cargo capacity across affected trade lanes
- Higher fuel prices linked to hostilities in the region
- Rerouting around restricted airspace, which extended flight times and operating costs
More recent data, however, indicates that global airfreight rate increases have largely eased as the market adjusts to a new operating environment following the U.S. and Israeli strikes on Iran at the end of February.
The wider impact extends well beyond aviation
With approximately a fifth of global oil supplies transiting through the Strait of Hormuz, prolonged uncertainty over when the conflict or diplomatic impasse will be resolved will keep energy prices elevated and ripple across supply chains worldwide.
International air cargo will be one of the many sectors affected by this crisis should hostilities continue over an extended period.
Every mode of transport, every manufacturer reliant on petroleum-based inputs, and every consumer-facing business with fuel-driven cost exposure will feel the impact.
Air cargo networks are adapting
Despite these challenges, air cargo networks continue to demonstrate the flexibility needed to support global supply chains as they adapt to overlapping geopolitical, tariff, and operational pressures. Carriers have responded by:
- Rerouting around restricted airspace
- Adjusting hub strategies in the Gulf region
- Reallocating capacity to maintain service on key trade lanes
That resilience has helped keep goods moving, even as transit times and costs have shifted.
What to watch — and what to do
All eyes remain on fuel supply and price, which are expected to test the industry’s resilience in the months ahead. Importers and exporters with airfreight in their supply chains should:
- Plan for continued rate volatility
- Build flexibility into freight budgets and lead times
- Work closely with their freight forwarder to identify the most cost-effective routing options as conditions evolve
How Universal Logistics can help
Universal Logistics continues to monitor developments in the Middle East and their impact on global air cargo markets. We are working closely with our airline partners and overseas agents to mitigate disruption and protect our clients’ supply chains.
For more information, contact David Lychek, Director – Ocean & Air Services.
Global Spotlight Quiz
Name the city that is home to Kapaleeshwarar Temple
- The city’s original name was Madras.
- Home to the country’s second largest container port, acting as a crucial hub for cars, containers and project cargo.
- A major manufacturing hub, the city accounts for a large portion of the country’s automobile industry, including the first BMW unit.
- Has one of the world’s longest urban beaches, Marina Beach.
- Home to the country’s oldest shopping mall, public zoo and prison.
Answer: Chennai, India
For more information about shipping freight to or from this city, contact Monserrat Vazquez, Manager – Freight Solutions.
Quick Tip
Country of Origin may not be the Country of Export
Did you know that Country of Origin and Country of Export are not the same thing? Country of Origin indicates where your product is made. Country of Export indicates where your product is shipped from. Failing to make this distinction could result in an AMPS penalty for incorrect tariff treatment.
At Your Service
Naara Garcia
Ocean & Air Clearances
Naara Garcia joined Universal Logistics in July 2021 as a member of our Head Office Customs Operations Ocean & Air Clearances team.
Naara is responsible for coordinating Full Container Load (FCL) and Less Than Container Load (LCL) clearances and deliveries, and her detail-oriented, client-focused approach continues to add value for our clients.
Naara can be reached by phone (905) 882-4880, ext. 1223 or by email.
Ocean & Air Clearances
SMART Logistics
Controlling how freight moves through your supply chain could save you thousands – or more.
Working with us means someone always asks: how can we make this shipment better?
Single-sourced trucking, customs clearance and distribution to expedite your freight shipments between the U.S. and Canada.
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Route is produced by Universal Logistics. Editor: Bettina Scharnberg. Email: bscharnberg@universallogistics.ca While every effort has been made to ensure the accuracy of information contained herein, Universal Logistics accepts no responsibility or liability for errors or omissions. Written correspondence should be forwarded to:
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