The U.S. Customs and Border Protection (CBP) is moving forward with an automated, four-step system designed to return approximately $166 billion in tariffs to over 330,000 importers. This massive refund effort follows a February 2026 Supreme Court ruling that declared duties imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful.
Here is a summary and rewrite of the current status of the refund process:
Overview of the Refund System
To manage the “unprecedented volume” of claims – which would otherwise require an estimated 4.4 million labor hours to process manually – CBP is developing a digital module called CAPE (Consolidated Administration and Processing of Entries) within the existing ACE trade portal.
The Four-Step Process
- Claim Submission: Importers will submit refund requests through a new portal in ACE. This will include automated checks to ensure data is complete and accurate.
- Mass Processing: Validated entries will move to an automated stage where IEEPA tariffs are removed and the correct duties are recalculated.
- Review and Liquidation: Entries will undergo a final review (liquidation or reliquidation) to finalize the specific refund amounts, including applicable interest.
- Electronic Issuance: Once finalized, refunds will be consolidated and issued electronically via Automated Clearinghouse (ACH) transfers. CBP will not issue paper checks.
Current Progress and Timeline
- System Status: As of mid-March 2026, the four functional areas of the CAPE system are reported to be between 40% and 80% complete.
- Launch Window: CBP estimate that the system could be operational within 45 days (roughly mid-to-late April 2026), though this timeline remains subject to testing and further court developments.
- Court Mandate: Judge Richard Eaton of the U.S. Court of International Trade has ordered that “every single cent” must be returned with interest. While he briefly paused an “immediate compliance” order to allow CBP time to build the automated system, the underlying refund mandate remains in effect.
Action Items for Businesses
- ACE & ACH Enrollment: Companies must ensure they have an active ACE account and are enrolled in ACH for electronic refunds. Payments to companies without these setups may be rejected.
- Data Readiness: Importers should begin compiling entry summaries, classifications, and proof of payment for all imports subject to IEEPA tariffs to ensure they are ready when the portal opens.
- Financial Planning: While the $166 billion represents a major liquidity injection for sectors like retail, manufacturing, and logistics, finance teams are advised to model various timing scenarios as the exact date for cash disbursements remains uncertain.