On March 6, 2026, the U.S. Court of International Trade received a filing from U.S. Customs and Border Protection (CBP) indicating that the agency is unable to meet the court’s requirement to immediately issue refunds for duties collected under the International Emergency Economic Powers Act (IEEPA) tariffs. Instead, CBP advised that the Automated Commercial Environment (ACE) system could be ready to process refunds within approximately 45 days.

Brandon Lord, Executive Director of the CBP Office of Trade, stated:

“With respect to any and all unliquidated entries that were entered subject to the IEEPA duties, U.S. Customs and Border Protection must liquidate those entries without regard to the IEEPA duties,” and that “any liquidated entries for which liquidation is not final shall be reliquidated without regard to IEEPA duties.”

CBP further indicated that it intends to develop new ACE functionality to facilitate the refund process. According to the filing, CBP believes this system will allow the agency to streamline and consolidate refunds and interest payments at the importer level, rather than issuing 53,173,939 individual entry-specific refunds, many of which would otherwise result in multiple payments to the same importer.

Proposed Refund Process

Based on CBP’s filing, the anticipated process may operate as follows:

• Importers will submit, through ACE, a list of entries for which IEEPA duties were paid.
• ACE will validate each entry and recalculate the duty owed without the IEEPA tariffs, including applicable interest.
• CBP will review and verify the calculations and begin processing refunds.
• ACE will finalize each entry by liquidating or reliquidating it accordingly.
• Verified refunds will be aggregated by importer number and liquidation date.
• CBP will certify the refund amounts.
• The U.S. Department of the Treasury will issue the refunds electronically.

Timing and Next Steps

CBP’s filing indicates that the full refund process could take several months to complete once implemented. It is important to note that this process has not yet been finalized and may change as CBP completes the necessary system programming.

At this time, refund requests cannot be submitted until CBP releases the final ACE functionality and procedures.

CV International will soon host a webinar providing guidance on how to run reports in ACE to gather the information needed to prepare for the anticipated refund requirements. An invitation with a registration link will be distributed soon.

As always, our Compliance Team is ready to assist you with any customs compliance needs.

Best Regards,

John Boomhover, LCB
Director of Compliance & Customs Services
CV International, Inc.