CBP Updates on ACE Portal Access and ACH Refunds

CBP has released the following message regarding the latest updates on ACE Portal account set-up and ACH refunds.

CSMS # 68179006 - REMINDER: ACE Portal Access and ACH Set-Up Required to Receive CBP Refunds

On February 6, 2026, U.S. Customs and Border Protection (CBP) transitioned to electronic-only refunds, as announced in the Electronic Refunds Interim Final Rule published January 2, 2026, in the Federal Register (91 FR 21). This change was necessitated by 31 U.S.C. § 3332 and President Trump’s March 25, 2025, Executive Order 14247, Modernizing Payments To and From America's Bank Account, 90 FR 14001.

Since February 6, 2026, CBP has had over 12,300 certified refunds rejected because the recipient party did not provide CBP the necessary banking information. If a refund recipient has failed to provide CBP valid U.S. bank account information in the Automated Commercial Environment Secure Data Portal (ACE Portal), CBP is unable to deliver electronic refunds to that recipient.

Importers and other parties who have had entry summaries liquidate since February 6, 2026, and have not yet provided CBP the necessary banking information to effectuate ACH refunds need to follow the instructions in the following ACH refund enrollment resources:

For technical questions, contact the ACE Account Services Desk at ace.support@cbp.dhs.gov. For general inquiries, contact the Office of Trade Relations at traderelations@cbp.dhs.gov.

If you have any questions, please contact our office.

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Important Update: IEEPA Refund Process Requirements

Key Steps to Protect Your Refund Eligibility

Recent guidance indicates that certain entries may require formal protest to remain eligible for IEEPA refunds. We encourage you to review your entries promptly and ensure your ACE account is properly set up to receive ACH refunds.

Please contact our office at compliance@iab-sd.com for questions.

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IEEPA Tariff Refund Updates - March 13, 2026

Please see the following message from Roll & Harris LLP regarding the latest updates on IEEPA tariff refunds.

IEEPA Tariffs Refunds / CIT Continues Oversight Over Possible ACE Portal Refund System / CBP to Report to CIT Again Next Week / Immediate Refunds Still Delayed / Government Appeal Still Possible

Yesterday, U.S. Customs & Border Protection (CBP) filed its status report to the Court of International Trade (CIT) regarding refunds of IEEPA tariffs. Recall that previously, the CIT had ordered CBP to refund IEEPA tariffs that were paid on UNLIQUIDATED entries and on entries for which LIQUIDATION IS NOT FINAL, but the CIT later suspended immediate compliance due to CBP reporting to the CIT how difficult such a process would be.

CBP previously advised the CIT that it contemplated building ACE functionality that would create the following refund process:

  • The importer files a declaration in ACE that includes a list of entries on which IEEPA duties were paid.
  • ACE runs a series of validations on each entry within the declaration and automatically re-calculates the duty owed without the IEEPA tariffs (with applicable interest).
  • CBP verifies the declaration and processes refunds as soon as practicable.
  • ACE automatically finalizes (liquidates or reliquidates) the entries.
  • ACE automatically aggregates the refunds with interest by importer and liquidation date.
  • CBP certifies the refunds
  • The Department of the Treasury issues IEEPA refunds electronically.

Yesterday's status report sheds more light on what CBP is doing, although many questions remain unanswered - particularly with regard to liquidated entries. Entries where liquidation is final likely must still be the subject of claims brought by litigation.

Per CBP's latest status report, the name for the ACE functionality will be "CAPE," which stands for Consolidated Administration and Processing of Entries. CAPE will have four (4) components to it:

  • A Claim Portal in ACE
  • Mass Processing
  • Review and Liquidation/Reliquidation
  • Refund

Importantly, CBP is proposing that importers will have the burden of applying for a refund claim. That is very different from CBP, who knows who has paid and how much was paid, proactively issuing refunds of illegally collected tariffs. Also note that, without an ACE account, the importer will be unable to make a claim, nor to receive a refund. Most importers still do not have their own ACE account with ACH refund functionality enabled.

CBP also contemplates that importers, not CBP, will have the burden of identifying the entries for which the importer wishes a refund. This burden will be met by the importer uploading a data file (in .CSV format) containing those entries and "all required information." Conspicuously absent from this status report is that CBP did not indicate what information would be required to make the claim. The "claim portal" portion is about 70% developed, per CBP. CBP did not provide a target date for anticipated 100% completion of the claim portal.

Next, the mass processing aspect of CAPE will involve CBP/ACE removing the IEEPA Chapter 99 Harmonized Tariff Schedule of the United States (HTSUS) classifications from the entries that were successfully uploaded in the Claim Portal and ACE will validate the duty calculation variances and accept (or not) the claim. This part of the CAPE process (mass processing) is only 40% complete per CBP. Again, no target date for anticipated 100% completion of the mass processing part of CAPE.

Once the duty calculations are validated, CBP anticipates that the CBP will proceed to liquidate or reliquidate on a specified number of days after the mass processing acceptance date. CBP states the liquidation/reliquidation part of CAPE is already 80% complete, but no target date for 100% completion.

Lastly, the CAPE system will direct refunds to occur on accepted CAPE refund declarations. Refunds will be consolidated per liquidation date/reliquidation date and importer of record. CBP advises this part of the CAPE system is only 60% complete. As above, there is not announced target date for 100% completion.

Per CBP's status report, the CAPE process, at least initially, will not cover antidumping/countervailing (ADD/CVD) entries, finally liquidated entries, nor entries that have a liquidation status of suspended, extended, or under review. Certain entry types also will not be covered (e.g., warehouse withdrawals and entries identified on drawback claims).

Judge Eaton continues to want to keep CBP on a short leash since he ordered CBP to provide another status report to the CIT on the new ACE functionality implementation by March 19th at 2 pm EST.

What does all of the above mean for importers? In our view, it means importers need still need to proceed with caution and control those aspects of the refund process that they can control, such as filing a refund lawsuit, filing protests, etc. This likely will continue to be our view unless and until the government fails to take a timely appeal and unless and until the government announces the CAPE refund process is "open for business." Even then, questions will remain around the types of entries that are NOT covered by the CAPE process, as well as what CBP will do with regard to entries that were (and continue to be) subject to bills for IEEPA tariffs, what CBP will do with regard to reconciliation entries, etc.

Practically speaking, it also means importers must be sure to apply for an ACE account and to enable ACH refunds in ACE once they have their ACE account.

If you have any questions, please contact our office.

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CBP Updates on ACE IEEPA Refund Programming

CBP has provided an update to the Court of International Trade (CIT) outlining the progress of its new ACE functionality that will support IEEPA refund claims without protests and PEAs.

Please see the following message from NCBFAA on more details about the new program called the Consolidated Administration and Processing of Entries (CAPE).

We will continue on providing further updates as this develops. We highly recommend setting up your ACE account to facilitate refunds.

CBP Outlines ACE IEEPA Refund Programming Progress to CIT Judge Eaton

Customs and Border Protection (CBP) today, March 12, provided an outline of its ACE IEEPA refund programming, so far, to Court of International Trade (CIT) Judge Robert Eaton. This new ACE functionality will be called the Consolidated Administration and Processing of Entries (CAPE), according to the filing submitted to CIT by Brandon Lord, Executive Director of Trade Programs for CBP’s Office of Trade.

The CAPE Claim Portal will be web-based and serve as the entry point for importers and customs brokers to submit IEEPA refund requests (“CAPE Declaration”) to CBP. Once operational, a new tab will be available in both importer and customs broker ACE Portal accounts.

CBP is designing CAPE with four integrated components:

  • Claim Portal,
  • Mass Processing,
  • Review and Liquidation/Reliquidation, and
  • Refund.

“These components reflect both how CBP anticipates refund requests will proceed through CAPE and how CBP is structuring its development efforts,” Lord said.

As of March 11, CBP estimates that its development of the Claim Portal component is 70% complete. Lord said, CBP has “finished developing the Claim Portal user interface and is currently developing the programming necessary to run the automated validations described above and provide information about validation errors to the CAPE Declaration filer.”

The agency said the CAPE Mass Processing component will “automatically remove any applicable IEEPA HTS numbers from the entry summaries submitted to and validated by the CAPE Claim Portal component. After the IEEPA HTS numbers are removed, the Mass Processing component runs the ACE duty calculation validations.” As of March 11, CBP estimates that its development of the Mass Processing component is 40% complete. “CBP’s development efforts are currently focused on the automated entry summary update process and related validations,” Lord said.

CAPE will also initiate the review and liquidation/reliquidation process for the entries identified in the accepted CAPE Declaration. This component will automatically set the entries to liquidate/reliquidate on a specified number of days from the acceptance date, allowing CBP to conduct a manual review as needed. CBP is developing additional functionality within this CAPE component to streamline any required agency review. It will also process liquidations/reliquidations of entries on a CAPE Declaration Monday through Thursday each week. CBP estimates that its development of the Review and Liquidation/Reliquidation component is 80% complete as of March 11.

When the entry summaries in the accepted CAPE Declaration reach the scheduled liquidation/reliquidation date, ACE will direct those entries to a CAPE-specific refund process within the ACE Collections refunds module.

As of March 11, CBP estimates that its development of the Refund component is 60% complete. CBP has completed developing CAPE-specific refund processing functionality within the ACE Collections framework. Currently, CBP is “performance testing” the CAPE refund consolidation process. CBP plans to complete additional development to further integrate the component with the other CAPE components and conduct additional performance testing in the next few weeks.

“CBP expects that in its first phase of development, CAPE will be able to process the majority of formal and informal entries on which IEEPA duties were paid, other than unliquidated entries subject to antidumping or countervailing duties, or entries for which the liquidation status in ACE is “Suspended,” “Extended,” or “Under Review,” and certain other entry types such as warehouse withdrawals, entries designated on a drawback claim, etc.,” Lord said. “CBP will provide detailed guidance to users regarding the scope and functionality of each phase of development as it is implemented.”

If you have any questions, please contact our office.

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Latest News on IEEPA Tariffs Refunds

Action Required: Set Up ACE & Activate ACH for Refunds

We are sharing updated information from Roll & Harris LLP regarding the latest developments on IEEPA tariffs refunds.

To ensure you are receiving refunds, please set up your ACE account and activate ACH refunds as soon as possible.

IEEPA Tariffs Refunds - Importers Win Round 1 Today, but Fight is Not Over

In what can only be described as a near complete win for importers, today, Judge Richard Eaton of the U.S. Court of International Trade (CIT) ORDERED U.S. Customs & Border Protection (CBP) to refund all IEEPA tariffs that were paid on UNLIQUIDATED entries and on entries for which LIQUIDATION IS NOT FINAL.

Judge Eaton noted that the government will have to pay interest on those refunds. For those wishing to listen to the audio of today's hearing, it is available here.

With regard to the entries where LIQUIDATION IS FINAL, the CIT set a closed (not public) conference for this Friday. Judge Eaton identified NOT FINALLY LIQUIDATED entries as those where liquidation happened less than 90 days ago since CBP, per 19 USC 1501, has 90 days from liquidation to voluntarily reliquidate an entry.

If the CIT's order stands - which remains to be seen - and if CBP complies - which also remains to be seen - CBP will have to liquidate every importer's UNLIQUIDATED entries, as well as every importer's entries where liquidation is NOT FINAL (liquidated less than 90 days ago), with refunds of the IEEPA tariffs. We note that is not a 100% complete refund of every IEEPA tariff as FINALLY LIQUIDATED entries are not covered by today's entries, but for most importers, it should result in the refund of the majority of the IEEPA tariffs paid.

In an ideal world, the above means that refunds would start flowing to importers as soon as 2 to 3 weeks from now since refunds usually follow liquidations and reliquidations about 2 to 3 weeks after the liquidation/reliquidation. That is, in an ideal world, CBP would comply with the CIT's order and begin, as early as this Friday (most regular liquidations occur on Fridays), to liquidate currently unliquidated entries without regard to IEEPA tariffs (i.e., refunds). Same for entries that liquidated within the last 90 days.

It is far from clear that we live in the ideal world. The best evidence of this is that toward the end of today's hearing, the government verbally asked for a stay of Judge Eaton's order so as to allow the government to immediately appeal. Judge Eaton summarily denied the government's request, but the government still has appeal rights. It remains to be seen whether it will exercise those rights and file an appeal.

We believe the government will surely appeal. We also anticipate the government will report to the CIT, as soon as Friday, that programming or other difficulties associated with liquidating the over 71 million entries that were filed in the last year with IEEPA tariffs prevents the government from immediately implementing the CIT's order (thus buying the government time to appeal). Surely, the government will argue on appeal that the CIT has no authority to order CBP to do anything with regard to importers who are not in court. If we are correct re the government appealing and the government slow rolling compliance with the CIT's order, then that means refunds will NOT flow immediately to importers.

It bears remembering that the government stated at today's hearing that it does not believe every importer is entitled to a refund of all the IEEPA tariffs an importer has paid. Judge Eaton reminded the government that "I'm not 100% sure that this will be CBP's decision" to make and that the law is 100% clear but that does not mean the government, absent direction from the White House, will simply waive the proverbial white flag on refunds.

Comments made by the Justice Department at today's hearing point to the fact that CBP (presumably at the White House's direction) does not want to issue full refunds to everyone, which is hardly a surprise. And while Judge Eaton has issued his order telling CBP to start refunding to all importers the IEEPA tariffs paid on unliquidated and not finally liquidated entries, it bears remembering that the appeals court will surely have something to say about today's order.

Lastly, Judge Eaton noted that the Chief Judge of the CIT (Chief Judge Mark Barnett) directed Judge Eaton to handle all of the 2100 cases that have been filed and stayed pending the outcome of the V.O.S. decision. As of this writing, Chief Judge Barnett has not assigned Judge Eaton the cases, but it now seems clear that the CIT judge who will oversee the refund process believes (1) the law is clear that the IEEPA tarifs were unlawfully collected and (2) that the IEEPA tariffs were void ab initio so everyone should get a refund.

How Judge Eaton's belief (and now order) will intersect with the White House's decision making and how it will play out on appeal, particularly with regard to those who have not filed suit yet, remains to be seen. While importers, particularly those who have filed a refund lawsuit, have scored an important victory today, the fight is not over.

We will continue to monitor developments and update you as the case progresses. In the meantime, importers who have not already taken action should consult with their regular trade/customs counsel re steps to take to best protect their rights to refunds, including whether it is advisable to immediately file a refund lawsuit, whether to file protests to attempt to keep liquidation from being final, etc.

Importers are also reminded to make sure they have an ACE account with ACH refunds enabled in ACE.

If you have any questions, please contact our office.

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Updates on IEEPA Refunds

IEEPA Refund Developments: Legal Considerations and Immediate Action Items

Please see the following message from Roll & Harris LLP regarding potential IEEPA tariff refunds and legal developments.

We strongly recommend that you consult with legal counsel to evaluate your specific circumstances, as reconciliation entries, drawback claims, and other factors may impact your protest strategy.

While IAB can assist with the preparation and filing of protests, it is highly advisable that you seek legal advice to get the exact language that would work best for your situation. Most importantly, you need to obtain an ACE Portal account and set it up to receive ACH refunds. Please keep in mind that filing protests may increase your bond liability so communication with your surety provider is important.

IEEPA Tariffs Refunds - Justice Department Signals Battle and Refund Delays Ahead

The U.S. Department of Justice filed a brief Friday night in the Court of Appeals for the Federal Circuit signaling that the government has no intention of moving quickly to refund illegally collected IEEPA tariffs. A copy of the government's brief may be downloaded here. Friday's filing relates to the timing of the appellate mandate, which is what transfers the case back to the U.S. Court of International Trade for the next steps in the litigation, but regardless of the mandate maneuvering, the following "highlight"/"lowlight" quotations from the government's filing ominously foretell fights ahead for importers and indicate that refunds will not be quick:

  • "Plaintiffs again claim the Court should speed ahead, but lack any good reason for that departure from an orderly process."
  • "Plaintiffs claim speed is of the essence because they suffer harm from being “forced to operate” without refunds in the interim. Mot. 5. But a compensable monetary loss is a classic harm that can be remedied by payment of money with appropriate interest, and a plaintiff’s bare desire to be paid immediately is not a basis to demand this Court comply with his every whim."
  • "Plaintiffs also claim hasty issuance of the mandate is necessary to “facilitate the refund process” in cases that are in the CIT already. The coming process will take time. Cf. U.S. Shoe Corp. v. United States, 29 C.I.T. 866 (Ct. Int’l Trade July 27, 2005) (refunds took seven years to fully be provided after United States v. U.S. Shoe Corp., 523 U.S. 360 (1998), even though the amount of money at issue there was substantially less than the amount at issue here."
  • "If anything, the Court should withhold issuance of the mandate for 90 days to allow the political branches an opportunity to consider options."
  • "Complexity in the future counsels appropriately careful process, not breakneck speed. The Court should deny the motion and if anything, withhold the issuance of the mandate for 90 days after the Supreme Court sends down its judgment to this Court"

The government's strategy appears to be to delay repayment as long as possible — until either the political climate shifts or a court forces its hand. To be sure, there are already several bills introduced in Congress but there is no veto proof support for such measures - at least not yet. This means that importers who have paid IEEPA tariffs should not expect voluntary, prompt refunds. Nor should they wait for clarity from the Executive Branch anytime soon. Instead, the path to recovery will likely require continued litigation and a direct court order from the U.S. Court of International Trade and importers should act accordingly.

NOTE: Despite press reports, the government's argument that refunding these tariffs would be complicated or burdensome is simply gaslighting to help in its efforts to refuse refunds. U.S. Customs & Border Protection (CBP) already has pre-built trade remedy reporting tools in its ACE (Automated Commercial Environment) system that can identify exactly how much any importer paid in tariffs — by shipment or in total. In addition, CBP can create (as it did in the Section 301 litigation) specialized reports in ACE to readily identify the amount of IEEPA tariffs paid by importer (since such payments are associated with a "9903" tariff number reported by the importer at the time of importation). Indeed, as the screen shots below show, such reports already exist:

 

 

The same tools used for Section 301, 201, and 232 tariffs can be applied here to identify how much illegal IEEPA tariffs CBP collected from each importer. Technically, refunds are straightforward and CBP has previously issued mass refunds to many importers, such as when the Generalized System of Preferences (GSP) program historically lapsed and Congress reinstated the program. See here and note this quote (see purple in linked webpage) from the GSP refund process, as an example:

Duty Refunds

A. Automation

Recognizing the impact that retroactive renewal and consequent numerous re-liquidations will have on both importers and CBP, CBP developed a mechanism to facilitate refunds for entries submitted during the lapse period using the Special Program Indicator (SPI) for GSP (with the letter "A," "A+," or "A*") as a prefix to the tariff number. We expect to begin automated processing of these shortly after the effective date.

Emphasis added. The obstacle is political will, not the mechanics of issuing automated refunds.

If you have any questions, please contact our office.

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by IAB Admin