U.S. Customs and Border Protection (CBP) has outlined a structured four-step process designed to refund importers for tariffs previously imposed under the International Emergency Economic Powers Act (IEEPA). The plan was detailed in a court filing submitted to the U.S. Court of International Trade as the agency works to implement the Supreme Court’s decision invalidating those duties last month.
The refund mechanism will operate through a new capability integrated into CBP’s Automated Commercial Environment (ACE), the digital portal used to finalize import entries. The system, known as the Consolidated Administration and Processing of Entries (CAPE), will manage the entire refund workflow.
The process will follow four stages: claim submission, mass processing of entries, review and liquidation or reliquidation, and finally the delivery of refunds to importers.
Under the first step, importers will submit refund claims through a dedicated portal. The system will automatically perform two validation checks to ensure the submitted information is complete and accurate. If discrepancies appear, importers will be able to review the issue and resubmit the claim.
Once validated, the system will remove the IEEPA tariffs from the affected entries and recalculate duties based on standard procedures excluding the cancelled tariffs. This stage of the system is still in the early development phase.
Following the recalculation, the platform will schedule liquidation within a defined number of days after acceptance of the claim. During this stage, the system will update the entries and calculate any interest owed.
Once liquidation is completed, refunds will be consolidated by liquidation date and transferred electronically back to the importers.
The development follows a recent directive from the Court of International Trade ordering CBP to liquidate pending entries and reliquidate unresolved ones without including IEEPA tariffs — the first judicial step toward enabling the refund process.
