CBP Offers IEEPA Tariff Refund Proposal to CIT

On March 6, 2026, U.S. Customs and Border Protection (CBP) provided the Court of International Trade (CIT) a response to the IEEPA refund order issued earlier in the week. While CBP is not ready to issue refunds today, they expect to have a streamlined process in place that will benefit importers and CBP alike in 45 days.

As a reminder, refunds will be processed electronically. According to CBP, only 21,423 of 330,566 entities have completed the set-up process to receive refunds electronically.

The declaration from CBP implies that this process might take months or more to complete the refunds to all affected importers.

“As of March 4, 2026, over 330,000 importers have made a total of over 53 million entries in which they have deposited or paid duties imposed pursuant to the International Emergency Economic Powers Act (IEEPA)”

CBP Plan of Action

CBP anticipates its ACE system updates will be ready to accommodate the refund processing of a massive amount of IEEPA entries in 45 days. When available, CBP will provide guidance on how to file refund declarations in the new system.

The system will be able to:

• Streamline and consolidate refunds and interest payments on an importer basis
• Minimize errors by ensuring accurate IEEPA refund calculations through system validations and allowing for a review period for CBP to resolve any discrepancies with the importer and to confirm no other outstanding enforcement issues or no revenue is owed.

CBP anticipates that the process will involve the following steps:

• The importer files a declaration in ACE that includes a list of entries on which IEEPA duties were paid.
• ACE runs a series of validations on each entry within the declaration and automatically re-calculates the duty owed without the IEEPA tariffs (with applicable interest).
• CBP verifies the declaration and processes refunds as soon as practicable.
• ACE automatically finalizes (liquidates or reliquidates) the entries.
• ACE automatically aggregates the refunds with interest by importer and liquidation date.
• CBP certifies the refunds.
• The Department of the Treasury issues IEEPA refunds electronically.

“Total amount of IEEPA duties and estimated duty deposits collected pursuant to IEEPA is approximately $166 billion”

What Actions Should Importers Take?

Establish an Importer ACE Portal Account

• Contact your NNR representative to add a Point of Contact to your 5106 Importer Record on file with U.S. Customs.
• Apply for an Importer ACE Portal Account
• Companies without an ACE Portal Account can use the automated application.

Authorize ACH Refunds

• For more information on how to authorize ACH Refunds see: ACE Portal – ACH Bank Information for Electronic Refunds

Download ACE Reports

• ACE Report ES-003 Entry Summary Line Tariff Details contains Entry Summary Data to help you determine the amount of IEEPA duties paid.
• ACE Report ES-701 Courtesy Notice of Liquidation can provide dates of liquidated entries
• Guidance on how to navigate ACE Reports is available here: ACE Training and Reference Guides | U.S. Customs and Border Protection

Questions?

We’re Here to Help – Reach Out to Your NNR Representative