U.S. Customs and Border Protection outlines system to issue refunds for invalidated IEEPA tariffs
U.S. Customs and Border Protection (CBP) has informed the U.S. Court of International Trade that it cannot immediately process refunds for tariffs imposed under the International Emergency Economic Powers Act (IEEPA) that were recently invalidated by the courts.
Instead, CBP has proposed a system-based refund process that could take approximately 45 days to implement.
Under the proposed approach, importers would submit a declaration through the Automated Commercial Environment (ACE). CBP would then recalculate duties, finalize affected entries, and aggregate refunds with applicable interest. Payments would ultimately be issued electronically by the U.S. Department of the Treasury.
Scope of Potential Tariff Refunds
At this stage, refunds are expected to apply primarily to entries that remain open or are still within the 90-day protest period following liquidation.
It remains unclear whether fully liquidated and final entries will qualify for refunds under the proposed process. Additional guidance from CBP and the courts is expected as the refund mechanism is developed.
The outcome will be important for importers seeking to recover duties paid under IEEPA tariff actions that have since been ruled invalid.
What Importers Should Do Now
Importers may want to take several steps while the refund process is being developed:
• Confirm ACE access and banking information are current
• Monitor entry liquidation dates closely
• Consider filing protests within 180 days of liquidation to preserve potential refund rights
How Alba Is Assisting Clients
Alba is actively reviewing entries and advising clients on tariff refund eligibility, protest strategy, and duty recovery opportunities related to the invalidated IEEPA tariffs.
Our customs and trade compliance specialists continue to monitor developments and will provide updates as CBP finalizes the refund process.
Reference
Declaration filed by U.S. Customs and Border Protection with the U.S. Court of International Trade indicating that development of a system to process refunds for invalidated IEEPA tariffs is expected to take approximately 45 days (reported March 6, 2026).
QUESTIONS ABOUT REGULATORY CHANGES?
Global trade regulations and compliance requirements continue to evolve, and staying informed is essential for importers and supply chain teams.
The Alba Wheels Up team closely monitors regulatory developments and works with clients to navigate complex customs, compliance, and supply chain requirements.
If you have questions about how regulatory changes may impact your imports or operations, our team is here to help.
Contact us to speak with an Alba compliance specialist:
https://albawheelsup.com/contact-us/
