As importing businesses in the United States await the Supreme Court’s decision on whether the International Emergency Economic Powers Act (IEEPA) grants the President authority to impose tariffs, importers should also consider a critical related question: are you properly prepared to receive a refund if one is granted?
Although it remains unclear who may ultimately be entitled to refunds—or whether refunds will be issued at all—the process for receiving any approved refunds is well defined and is undergoing a significant transition.
On March 25, 2025, President Trump issued Executive Order 14247, which mandates the modernization of all federal disbursements and receipts by transitioning from paper checks to electronic payments, to the extent permitted by law. Historically, importers submitted written protests at their local U.S. Customs office and, upon approval, received a paper refund check by mail. As federal payment systems continue to modernize, this process has evolved accordingly.
Beginning February 6, 2026, U.S. Customs and Border Protection (CBP) will issue refunds exclusively through the ACH Refund Authorization tool within the Automated Commercial Environment (ACE). Paper checks will no longer be issued unless a company can demonstrate that the electronic process creates a financial hardship (see code). Refunds will be deposited directly into a U.S.-based bank account designated in the importer’s ACE profile.
For importers who do not wish to establish an ACE account, an alternative option is available. By completing CBP Form 4811, an importer may authorize a third party—such as a customs broker—to receive refund payments on their behalf. Importers should be aware that customs brokers typically charge a fee for providing this service.
All refund-related requests, including protests and post-summary corrections, are now filed electronically through the ACE portal, generally by the importer’s customs broker. Once approved, refunds are processed through the importer of record’s ACE account, which must be enrolled in the ACH Refund program in order to receive funds.
Importers without an existing ACE account will need to register for one. The process is straightforward and free of charge. In addition to enabling electronic refunds, an ACE account provides access to valuable tools, including online entry visibility, reporting capabilities, bond renewal tracking, and other compliance-related information. Apply for ACE account here.
After creating an account—or if one already exists—importers must enroll separately in the Electronic Refund (ACH) program. Additional information is available through CBP’s “Modernizes Electronic Refund Enrollment Process” guidance.
If refunds related to IEEPA tariffs are ultimately authorized, the filing window is expected to be narrow. Importers should be prepared by identifying how many entries they have filed since April 1, 2025, which entries included IEEPA tariffs, and the corresponding amounts paid. In many cases, customs brokers may need to file protests to recover these duties. Since each protest may include no more than five entries, refunds may be issued in multiple ACH deposits.
In conclusion, importers are strongly encouraged to review and update their ACE accounts to ensure that the ACH Refund Authorization is active and that accurate banking information is on file. Taking these steps now will help ensure that any future refunds issued by U.S. Customs and Border Protection are received promptly and deposited into the correct bank account.
Best Regards,
Director of Compliance & Customs Services