Toronto, March 20, 2026
IEEPA Refunds – Here’s What You Need To Know
Following a Court of International Trade (CIT) order directing U.S. Customs and Border Protection (CBP) to begin refunding International Emergency Economic Powers Act (IEEPA) tariffs, CBP has outlined a new process and system to facilitate those refunds. This alert summarises the key developments and the steps importers should take now to ensure they are ready to receive refunds without delay.
Background: Key Developments
4 March 2026 – The CIT issued an order directing CBP to begin the process of refunding all tariffs collected under IEEPA.
6 March 2026 – CBP advised the CIT that it was unable to issue refunds immediately and was developing a new system to process claims, which was estimated to take approximately 45 days to complete. CBP also confirmed that, as of 6 February 2026, all refunds are issued electronically via Automated Clearinghouse (ACH) only.
12 March 2026 – The CIT required CBP to provide a progress report. CBP confirmed that the new CAPE portal (see below) is currently 70% complete, with the processing component estimated at 40%.
CBP’s New Refund System: CAPE
CBP is building a new system, the Consolidated Administration and Processing of Entries (CAPE), which will be the dedicated platform for processing IEEPA tariff refunds. Key features include:
- Importers and their brokers will be able to upload a CSV file listing the entries for which IEEPA refunds are being requested.
- CAPE will validate the CSV file against Automated Commercial Environment (ACE) and the relevant entry data.
- Refund amounts will be calculated as the IEEPA duty paid, less the applicable Chapter 1–97 duty that would otherwise be owed.
- Upon review, CAPE will initiate liquidation or reliquidation for the listed entries and will automatically set liquidation/reliquidation dates based on the date the CAPE declaration is accepted.
- CBP will retain a review period between acceptance of the CAPE declaration and the new liquidation date to manually review entries as required.
- CAPE will be released in phases, with components made available to the public as they are completed.
CBP’s Position (Declaration of 6 March 2026):
“CBP is making all possible efforts to have this new ACE functionality ready for use in 45 days. This new process will require minimal submission from importers. It will also minimize errors by ensuring accurate IEEPA refund calculations through system validations and by allowing a review period for CBP to resolve any discrepancies with the importer and confirm that no other outstanding enforcement issues exist or that no revenue is owed. The process will be simpler and more efficient than the existing functionalities, and CBP will provide guidance on how to file refund declarations in the new system.”
Action Required: Steps to Take Now
While the CAPE system is being finalized, importers should take the following steps now to ensure they are ready to receive refunds without delay.
Step 1: Enrol in the ACH Refund Program on ACE
As of 6 February 2026, CBP issues all refunds electronically via ACH only. Importers must have an ACH set up in ACE with a valid US bank to receive refunds.
- Log in to the ACE Portal and confirm your ACH refund banking information is accurate and up to date.
- If not yet enrolled, submit an ACH Refund Program application through ACE and designate a US bank account. Importers already enrolled do not need to reapply.
- If you are currently on PMS (Periodic Monthly Statement), you will still need to add your banking information under the ACH Refunds tab in ACE.
- 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 to CBP in lieu of filing through the portal.
Step 2: Confirm Access to Your ACE Account (Top Account)
Having an Importer of Record (IOR) number does not automatically grant access to your trade data in ACE. A “Top Account” application must be submitted separately to link your IOR number to your ACE profile.
- Sign up for or confirm your ACE Portal account. Instructions are available here.
- If a CBP Form 5106 was previously filed on your behalf, the contact details on that form may need to be updated, as ACE Portal accounts can only be set up by the person whose contact information appears on the 5106.
- Establishing a Top Account gives importers direct access to their trade data at any time, reducing reliance on a customs broker to retrieve information on their behalf.
How Universal Logistics Can Help
We are available to assist you with:
- Setting up or verifying your ACE Portal account and Top Account access
- Enrolling in or updating your ACH Refund Program details
- Acting as the Notify Party for importers without a US bank
- Preparing and submitting entries via CAPE once the system is live
- Reviewing your entry data to identify and quantify potential IEEPA refunds
For more information, please call Matthew Williamson, Consultant – Trade Advisory – Customs Consulting Services at (716) 882-4100, ext. 2609.
