Urgent IEEPA Filing

Please contact our office if you need assistance in filing your CAPE declarations for IEEPA Refunds.

You can reach us at compliance@iab-sd.com for questions.

by IAB Admin

Important Reminder: ACE Portal Access and ACH Refunds

As April 20th is quickly approaching, that is the day we can begin uploading reports into the CAPE system for IEEPA Refunds.

It is essential to have your ACE account set up for ACH refunds. Please refer to the instructions below for guidance.

IAB will be able to help with the process of uploading reports into the CAPE system for you when it is functional.

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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by IAB Admin

Notice on CAPE for IEEPA Refunds

Important Message about CAPE for IEEPA Refunds

The following notice from CBP regarding processing of entries for IEEPA refunds.

CSMS # 68315804 - Introduction - Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026 Deployment

On April 20, 2026, U.S. Customs and Border Protection (CBP) will launch the first phase of the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment Secure Data Portal (ACE Portal). CAPE will simplify International Emergency Economic Powers Act (IEEPA) duty refund requests made pursuant to court order and in accordance with appropriate statutory authority by providing an electronic pathway to submit valid IEEPA duty refund claims.

CAPE is designed to consolidate refunds of IEEPA duties including interest rather than processing refunds on an entry-by-entry basis. CBP plans to implement CAPE through a phased development approach, adding more functionality in subsequent phases for more complicated scenarios. CAPE Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation.

Requesting refunds of IEEPA duties requires only the following summarized actions:

  • Importers of Record (IORs) and authorized Customs brokers have an established ACE Secure Data Portal account (ACE Portal account)
  • Refund recipients use the ACE Portal account to provide CBP with bank account information for refunds
  • IORs and authorized Customs brokers submit CAPE Declarations in the ACE Portal

The CAPE process starts with the filing of the CAPE Declaration in the ACE Portal by the IOR or the authorized broker who filed entries on behalf of the IOR. Once accepted, CBP will remove the IEEPA Harmonized Tariff Schedule number and recalculate the duties due without IEEPA, updating the entry to a new version. CBP will review the updated version of the entry and liquidate or reliquidate. Refunds will be consolidated by IOR or the party designated via CBP Form 4811 and liquidation date.

IORs and brokers who will be filing CAPE Declarations are encouraged to prepare for CAPE filing by ensuring that they have an ACE Portal account and that their bank account information for refunds has been added to their account. For additional information about ACE Portal access and ACH refunds visit the resources below:

To learn more about CAPE functionality in ACE, please see the CAPE Information Notice. For more information on the CAPE filing process, please see the CAPE Refund Quick Reference Guide.

CBP will continue to issue messaging via the Cargo Systems Messaging Service (CSMS) to ensure the trade community is informed and prepared to utilize this new tool and as new enhancements are deployed.

Technical questions regarding this message should be directed to IEEPARefunds@cbp.dhs.gov. General questions regarding this message should be directed to traderelations@cbp.dhs.gov.

If you have any questions, please contact our office.

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by IAB Admin

Action Required - Important Security Information

Please Complete and Return this CTPAT Questionnaire

As a member of CTPAT, IAB would like to highlight the importance of security procedures in place to ensure that your shipments do not get compromised.

Please see the following guide for more information, complete the attached questionnaire and submit this form back to us:

If you have any questions, please contact our office.

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by IAB Admin

New Section 232 Tariff Actions on Pharmaceuticals and Metals

President Issues New Pharma Tariffs and Revises Metals Section 232 Measures

President Trump issued two significant proclamations under Section 232 impacting pharmaceutical imports and modifying existing tariffs on metals and derivative products. Below is a summary of the key provisions, timelines, and considerations for importers provided by Sidley Austin LLP.

We will continue to provide updates as new information is being released. If you have any questions, please contact our office.

Earlier today, President Trump signed two proclamations related to tariffs: one imposed new tariffs on imported pharmaceuticals and pharmaceutical ingredients pursuant to Section 232 of the Trade Expansion Act of 1962 (“the Pharma 232 Proclamation”); and the other modified the tariffs previously imposed on imported aluminum, steel and copper (and derivative articles thereof) pursuant to Section 232 (“the “Modified Metals 232 Proclamation”).

For your reference, copies of the proclamations, including the annexes, are attached:

At a high level, the Pharma 232 Proclamation imposes a 100% tariff on patented pharmaceuticals and associated ingredients, but exempts (fully or partially) wide swaths of the industry. For example, products of countries that have agreements with the United States will be subject to a tariff of 15% (Japan, the EU, Korea, Switzerland and Liechtenstein) or 10% (UK); companies that have negotiated an on-shoring agreement with the Department of Commerce will be subject to a 20% rate initially and that rate will jump to 100% in 2030; companies that have negotiated an agreement with Commerce and a most-favored-nation pricing agreement with the Department of Health & Human Services will be subject to a 0% rate until January 20, 2029; certain categories of products (e.g., orphan drugs, nuclear mediciines, PDTs, fertility treatments, cell and gene therapies; antibody drug conjugates; medical countermeasures related to chemical, biological, radiological, and nuclear threats, animal health pharmaceuticals) also appear to be eligible for 0% treatment if one of more conditions are satisfied.

Generics not subject to these tariffs at this time, but that will be reviewed in 1 year. U.S.-origin pharmaceuticals are not subject to these tariffs – and this is important given how the customs rules of origin for pharmaceuticals work. There are a lot of details in both the proclamation and in the annexes. We recommend reviewing them all.

Companies (and countries) that have not yet negotiated a lower rate, will have the opportunity to do so. The tariffs imposed by this proclamation are effective July 31, 2026 for companies listed in Annex III and September 29, 2026 for everyone else (this is probably to give companies extra time to obtain an agreement that provides for a lower rate).

As for the Modified Metals 232 Proclamation, it modified the tariffs with regard to so called “derivative articles” – i.e., articles that contain aluminum, steel or copper as a component. The proclamation removed certain derivative articles from the scope of the Section 232 tariffs. It also addressed an issue that has bedeviled importers – how to calculate the dutiable metal content when the imported article includes metal and non-metal components – by requiring the tariff to be applied to the entire value of the covered article, regardless of metal content.

The President also terminated the “inclusion process” which had allowed companies to request that Commerce add additional products to the list of articles subject to these tariffs and replaced it with an interagency process for inclusions. According to the White House, the proclamation “establishes clear rules” for determining the Section 232 tariffs for aluminum, steel and copper:

  • Articles made entirely or almost entirely of aluminum, steel, or copper will pay a flat 50% on their full value -- for example, steel coils and aluminum sheet.
  • Derivative articles substantially made of steel, aluminum, or copper will pay a flat 25% on their full value.
  • Certain metal-intensive industrial equipment and electrical grid equipment will pay 15% through 2027, to accelerate the massive industrial base buildout currently underway across the United States.
  • Products made abroad but entirely with American steel, aluminum, and copper will be subject to lower tariffs of 10%.
  • Products made of 15% or less steel, aluminum, or copper will no longer be subject to Section 232 metals tariffs.

The changes made by this proclamation are effective April 6, 2026.

Stay Updated on Customs Compliance

by IAB Admin

IEEPA Refund Process Updates

The following notice from Tuttle Law provides updates on the evolving IEEPA tariff refund process.

IEEPA Refund Process Update - March 31, 2026

This is an update on recent legal developments on the International Emergency Economic Powers Act (IEEPA) Tariff refund process as of March 31, 2026.  Late last week the U.S. Court of International Trade (CIT) ordered Customs and Border Protection (CBP) to include finally liquidated entries in its Consolidated Administration and Processing of Entries ( CAPE) program. CBP, however, recently advised the court that it cannot at this time include finally liquidated entries, setting the stage for further fireworks between the court and CBP.

On March 27, 2026, Senior Judge Richard Eaton of the CIT issued an order in Atmus Filtration Inc. v. United States, updating his previous order of March 20, 2026, regarding refunds of duties paid under IEEPA.

The March 27, 2026 order broadens the scope to include finally liquidated entries, encompassing those entries that have completed both the 314-day liquidation cycle as well as the 180-day protest period during which importers can challenge the final assessment of duties imposed by CBP by the protest procedure (19 U.S.C. §1514). Under this new order, the implication is that importers will not be required to file protests for entries that are beyond the date of finality in order to recover the IEEPA duties (“Any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties.”). In the March 27, 2026 order, the judge ordered CBP to:

  • Liquidate all entries that have not been liquidated with an IEEPA refund.  (This is the CAPE process that is still under development by CBP.  (An entry typically liquidates at the 314th day following the date of entry and this information can be included on the importer’s ACE report).
  • The judge also ordered CBP to not only reliquidate any entry that has liquidated but for which the liquidation is within CBP’s voluntary reliquidation period of 90 days, or before 404th date following the date of entry, but to reliquidate any entry that has liquidated, regardless of whether the liquidation is final or not, if IEEPA duties were deposited.

The court’s March 27, 2026 order can be viewed here.

On March 30 CBP filed its status report with the CIT, where it stated that

“in order to  meet the timeline for Phase 1 deployment … CBP must continue developing Phase 1 of CAPE without the inclusion of finally liquidated entries. ... Phase 1 will only process unliquidated entries and entries within the 90-day voluntary reliquidation period.”

Understanding The CAPE Program

In a declaration presented to the Court by the Executive Director, Trade Programs Directorate, Office of Trade, U.S. Customs and Border Protection (CBP) (Brandon Lord), the CAPE Program was explained as consisting of four integrated components:

1. Claim Portal

  • The CAPE claim portal will be a new web-based tool in ACE for importers and brokers to submit IEEPA refund requests.
  • Filers will submit claims by uploading a CSV file listing the entry summaries for which refunds are requested.
  • ACE will perform file-level validations, such as checking whether the submission is complete, properly formatted, submitted by the correct party, and not corrupted.
  • If the file fails validation, ACE will reject the entire submission and identify the errors so the filer can correct them and resubmit.
  • If the file passes, ACE will then review each listed entry, including whether the entry exists in ACE and includes an IEEPA Chapter 99 tariff number.
  • Entries that fail these checks will be removed, but the remaining entries will continue through the process.
  • Filers will be able to review rejected entries and resubmit them separately if the issues can be corrected.

2. Mass Processing

  • For validated entries, the CAPE Mass Processing component will remove the applicable IEEPA tariff numbers from the entry summaries.
  • ACE will then rerun its normal duty calculations.
  • In effect, the system will recalculate duties as if the IEEPA duties had never been declared.
  • Once that process is complete, the CAPE Declaration will be accepted.

3. Review and Liquidation/Reliquidation

  • After acceptance, the entries will move to review and liquidation or reliquidation.
  • ACE will schedule the entries for liquidation or reliquidation a set number of days after acceptance, while still allowing CBP to conduct manual review if needed.
  • The system will update the entry summaries to reflect the revised duty amounts and will automatically calculate any applicable interest.
  • CBP states that CAPE liquidations and reliquidations will be processed Monday through Thursday.

4. Refund

  • On the scheduled liquidation or reliquidation date, ACE will send the entries to a CAPE-specific refund process in the ACE collections module.
  • Refunds will be grouped by liquidation or reliquidation date and by importer of record, or by a Form 4811 designee.
  • Once processed, the refunds will be issued electronically to the designated bank account.

CBP’s CAPE program is still in development. The expected date of completion is April 20th, and then there may be testing that is subsequently required. We don’t know as of yet the final date as no information has been released by CBP at this time.

Supposedly, a phased rollout is planned so as to manage the high volume of claims.

As an importer seeking your IEEPA refunds, the first order of business is to access your ACE Portal account to obtain a list of all entries that you have paid IEEPA duties on. In your query you may wish to include other information, such as date of entry, date of liquidation, Chapter 9903 line items, duties paid and Chapter 99 HTUS classification. This is key because it will identify the process to follow for each entry and allow you to validate CBP’s subsequent actions with regard to your IEEPA refund requests. If you wish, we can assist with this.

In the meantime, CBP has indicated that entries will continue to liquidate on the 314th day. This means that the clock is continuing to run with respect to the liquidation of entries, and their horizon of timeliness. If your entry is currently approaching your event horizon of timeliness (the 494th day) and either CAPE is not ready or you have not filed your CAPE submission, it is advised that you file a protest against the liquidation as a means to protect your right to a refund.

What if the liquidation of my entry has already occurred and the liquidated entry has already past or is closely approaching its 180th day following liquidation? If the entry has reached its date of finality or will do so before the anticipated operational date of CAPE, you should consult with your Customs or trade counsel as to whether you should file a summons and complaint in the CIT asserting jurisdiction under 28 U.S.C. §1581(i), so that it may be in a position to order CBP to refund the duties on those finally liquidated entries that are now beyond the protest period. While the court may be emphatic that the process will cover all entries whether finally liquidated or not, a Judge’s decisions or orders are subject to appeal.

Please keep in mind that imports from China were assessed with IEEPA duties beginning on February 4, 2025, at 10%, which then increased to 20% and so on in March of 2025. IEEPA duties on products from Canada and Mexico, not otherwise eligible under USMCA began in March of 2025. These dates are important as imports from China entered the liquidation cycle on or about December 25, 2025 (or earlier). The 90 day re-liquidation cycle would begin to end on March 25, 2026, and finality of liquidation occurs on June 23, 2026.

The rest of the world began the payment of IEEPA duties in April, 2025. These entries started to liquidate on February 13, 2026, and will be available for CAPE for 180 days following the actual date of liquidation.

Judge Eaton’s order of March 27, 2026, is very helpful in clarifying and simplifying the process associated with requesting refunds for the majority of IEEPA tariffs paid, even if it will take longer to develop refund processes for more complex entry types, including reconciliation, drawback, warehouse entries, surety payments, and postal informal entries.

If you have any questions, please contact our office.

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by IAB Admin