Dear Customers, Colleagues, and Friends,
We want to provide an important update regarding the refund process for duties paid under the International Emergency Economic Powers Act (IEEPA). Recent developments from the U.S. Court of International Trade (CIT) have expanded the scope of eligible refunds, which is a positive step for importers seeking recovery of these duties.
What Has Changed
A court order issued on March 27, 2026 significantly broadens eligibility for refunds:
- IEEPA Refunds may now apply to all entries, including:
- Unliquidated entries
- Recently liquidated entries (within 90 days)
- Even fully liquidated entries that are past the protest period
In practical terms, this means:
- Importers may not need to file protests to recover IEEPA duties in many cases
- U.S. Customs and Border Protection (CBP) has been directed to reprocess entries and remove IEEPA duties where applicable
How Refunds Will Work (CAPE Program)
CBP is developing a new system called CAPE (Consolidated Administration and Processing of Entries) to handle refunds.
- Claim Submission
- Importers or brokers will submit refund requests through CAPE (Within the ACE portal)
- Submissions will include a list of affected entries through a specified report in ACE
- Recalculation of Duties
- CBP will remove IEEPA tariff lines
- Duties will be recalculated as if IEEPA never applied
- Review & Processing
- Entries will be reviewed and scheduled for liquidation/reliquidation
- CBP may manually review certain entries if needed
- Refund Issuance
- Refunds will be issued electronically to the importer’s designated account (Must be USA based bank account)
Important Limitation
While the court ruling includes all entries, CBP’s initial rollout will be limited:
Phase 1 of CAPE will only handle:
- Unliquidated entries
- Entries within the 90-day reliquidation window
- ***Processing for fully liquidated (final) entries will come later
What This Means for You
- There is a more clear path to recover IEEPA duties
- Expect be delays and phased implementation as CBP builds out CAPE
- Register for your ACE account and apply for an electronic refund authorization
**** It is EXTREMELY IMPORTANT to review previous Customer Advisories ( 1/13/26 & 2/4/26) linked here to review the updated tariff refund procedure. We strongly suggest immediately registering for an ACE Portal account, if you haven’t already, and following the ACH REFUND AUTHORIZATION procedure.
Sincerely, Your friends at Krenz and Hannan International