Countdown to CBP Tariff Refunds Begins: Next Steps for Importers of Record and Commercial Customers

Refund ruling creates two categories of potential refund eligibility

The Court of International Trade struck down IEEPA tariffs and mandated refunds for affected entries, then paused its order to give CBP time to build a refund process capable of handling such a large volume of refunds. The agency is now developing an automated electronic refund system to return the money with interest, but your account must be configured correctly to receive it.

However, the structure of the refund process is important. CBP will issue refunds only to the importer of record (IOR) listed on the customs entry. That means businesses affected by the tariffs generally fall into two groups:

• Importers of Record, who paid the tariffs directly to CBP
• Commercial customers, who absorbed tariff costs through supplier pricing or landed-cost charges

Understanding which category your business falls into will determine how you should prepare.

Determine Direct/Indirect Exposure

How the CBP tariff refund (should) work

CBP is building an automatic refund mechanism within the familiar Automated Commercial Environment (ACE). Once operational, the system is expected to identify qualifying entries and process refunds electronically without requiring importers to submit individual claims.

Refunds will be:

• Issued through the ACE portal
• Consolidated by importer of record number
• Paid electronically through ACH deposits
• Calculated to include interest from the original payment date

Under normal circumstances, importers would need to file protests and wait months for resolution, but under the new system, CBP will identify qualifying entries and distribute refunds automatically.

However, businesses must ensure their ACE accounts are configured correctly, particularly for ACH payments. If electronic payment settings are not established, refunds may be delayed.

If you were the importer of record

If your company served as the importer of record on entries where IEEPA tariffs were paid, you will likely qualify for an automatic refund once the system is implemented.

Refunds apply specifically to tariffs imposed under IEEPA authority, including:

• Reciprocal tariffs targeting goods from specific countries
• Additional duties imposed under IEEPA emergency declarations
• Entries where IEEPA tariffs were paid during the affected period

The refund will include both the tariff amount and accrued interest.

Even with automatic processing, it is important to review your records to ensure tariffs were applied accurately and that all qualifying entries are included in the refund calculations.

Steps importers should take now

While CBP finalizes its system, importers can take several steps to prepare.

Reconcile tariff payment records: Gather documentation for all IEEPA tariffs paid during the affected period, including entry summaries, payment confirmations, and customs broker records.

Verify ACE portal access: Confirm that you have active access to the ACE portal under your importer of record number. Many importers rely on their customs brokers and have never accessed ACE directly.

Enable ACH refund capability: CBP will issue refunds electronically through ACH deposits. Ensure your ACE account is configured with current banking information to avoid delays.

Coordinate with your customs broker: Your broker likely filed the original entries and maintains detailed records of your tariff payments. Request a summary of affected entries, including entry numbers, duty amounts, and liquidation status.

If your business was not the importer of record

Many businesses affected by IEEPA tariffs were not listed as the importer of record but still absorbed increased costs through supplier pricing, landed-cost charges, or duty reimbursements.

Because CBP will issue refunds only to the importer of record, these businesses will not receive refunds directly from the government.

This creates a gap between who paid the economic burden of the tariff and who receives the refund.

Non-IOR path to recovery may depend on supplier agreements

Businesses that absorbed tariffs indirectly may still have a path to recovering those costs through the party receiving the refund.

The strength of that position typically depends on:

• Contract terms governing duty or tariff pass-through
• Documentation showing reimbursement of duties
• The nature of the commercial relationship with the importer of record

If supplier agreements clearly state that tariffs are passed through, or if documentation shows the customer reimbursed the importer of record for those duties, there may be a reasonable basis to request that refunds be returned once received.

Recovery becomes more complex when contract language is unclear, the relationship has ended, or the importer of record is unresponsive.

In these situations, recovery may require formal requests, negotiation, or legal action.

Steps commercial customers should take now

Businesses affected by IEEPA tariffs but not listed as the importer of record should begin preparing by:

• Identifying shipments that included IEEPA tariff charges
• Determining who served as importer of record for those entries
• Collecting purchase orders, invoices, and reimbursement documentation
• Reviewing supplier agreements for tariff pass-through provisions

Once this information is assembled, it may be helpful to contact the importer of record to discuss the expected refund process and confirm whether those funds will be passed through once received.

Establishing expectations before refunds begin to flow often leads to better outcomes than addressing the issue after payments have already been issued.

Positioning your business for refund success

IEEPA refunds represent one development within a broader and evolving tariff environment. While these tariffs have been invalidated, other trade measures, including Section 232, Section 301, and Section 122 tariffs, remain in effect.

For many mid-market companies, the refund process presents an opportunity to reassess overall tariff exposure and supply chain strategies, not just past duties but also future mitigation opportunities.

Businesses that take the time to understand their exposure, review documentation, and coordinate with supply chain partners will be better positioned as the refund process moves forward.

Take our brief tariff refund eligibility assessment to understand which category you fall into and how you can start preparing.

Assess My Refund Eligibility

Common mistakes that could delay your refund

Missing electronic refund setup

The most frequent problem is failing to establish ACH capability before refunds start processing. CBP has stated that refunds will be rejected if electronic payment isn't set up, there's no manual option.

Incomplete entry documentation

Discrepancies between your records and CBP's data can trigger delays. Reconciling your records now gives you time to identify inconsistencies and work with your broker to resolve them before refunds begin processing.

Waiting for customs broker notification

While brokers play an important role, the importer of record bears responsibility for account setup and refund receipt. Taking a proactive approach, rather than waiting to be contacted, typically leads to faster resolution and fewer surprises.