Big News: IEEPA Tariff Refunds are Hitting Bank Accounts

The wait is finally over. After months of legal battles and a massive administrative buildup, we are seeing the first wave of IEEPA tariff refunds land in importer bank accounts.

Earlier this year, following the U.S. Supreme Court decision in Learning Resources, Inc. v. Trump, the "emergency" tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were struck down. Since then, U.S. Customs and Border Protection (CBP) has been working under court supervision to build the CAPE (Consolidated Administration and Processing of Entries) platform—a specialized system designed to return an estimated $166 billion to over 330,000 importers.

Here is what you need to know about the money moving right now.

1. Phase One is Officially Live

As of May 12, 2026, the U.S. Treasury began issuing the first batch of Automated Clearing House (ACH) refund payments. This initial phase focuses on roughly 63% of eligible entries, specifically:

  • Unliquidated entries: Shipments currently in the system that haven't been finalized.

  • Recent Liquidations: Entries liquidated within the last 80 days.

  • Suspended/Extended entries: These can be filed now, though they will liquidate in their normal course.

2. No More Paper Checks

If you are expecting a check in the mail, you’ll be waiting indefinitely. Effective early 2026, CBP transitioned to a mandatory electronic refund rule. To receive your funds, you must have:

  • An active ACE (Automated Commercial Environment) Portal account.

  • Updated ACH Refund information (Form 5106) configured in the portal.

Note: Many importers who use ACH to pay duties are surprised to find they aren't set up to receive refunds. If your bank info isn't "Green" in the ACE portal, your payment cannot be transmitted.

3. The "CAPE Declaration" is Required

Unlike standard entry liquidations containing a duty refund, these refunds aren't entirely automatic. Importers or their authorized brokers must upload a CAPE Declaration (a CSV file containing up to 9,999 entries) via the ACE portal.

  • Validation Matters: About 15% of initial filings are being rejected due to data mismatches.

  • The Timeline: Once a declaration is accepted, refunds are typically issued within 60 to 90 days.

4. Interest is Adding Up

There is a silver lining to the wait. The Court of International Trade confirmed that these refunds must include statutory interest. With interest rates for the current quarter sitting at roughly 6% for corporations and 7% for non-corporations, the total recovery for many companies is significantly higher than the raw tariff amounts originally paid.

What Should You Do Now?

If you haven’t seen a deposit yet, don’t panic—but do be proactive. The difference between a quick payout and a long administrative delay often comes down to your paperwork being in perfect order.

  • Check your ACE Portal: Ensure your ACH info is verified and ready for deposits.

  • Talk to your Broker: Confirm they have filed the CAPE Declaration for your eligible entries.

  • Identify Exclusions: Entries flagged for reconciliation, drawback, or those liquidated more than 80 days ago are generally excluded from Phase 1. You need a strategy for when Phase 2 opens.

    • Phase 2 entries are also not included in Phase 1.

Need Help Navigating the CAPE System?

The refund process is complex, and even a small data mismatch can lead to a rejected claim. Our experts are ready to help you secure your funds as quickly as possible.

We provide hands-on assistance with:

  • ACE Account Setup & Optimization: We’ll ensure your portal is correctly configured for ACH refunds so the money hits your account without delay.

  • CAPE Filing Management: From data validation to submission, we handle the heavy lifting of filing your declarations for thousands of entries.

Don’t leave your recovery to chance. Reach out to us today to get your filing started and ensure your business gets back every dollar it's owed

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Great News on CAPE Phase 1 Refunds!