We are continuing to monitor developments related to IEEPA tariff refunds under the International Emergency Economic Powers Act, particularly in light of recent legal and administrative updates.
In February, the U.S. Supreme Court ruled certain IEEPA tariffs unlawful. As a result, the U.S. Court of International Trade directed U.S. Customs and Border Protection (CBP) to issue refunds to importers of record.
CBP is currently developing a new process within its existing Automated Commercial Environment (ACE) system, referred to as the Consolidated Administration and Processing of Entries (CAPE), to calculate and distribute these refunds.
CAPE Development Status (as of March 30, 2026):
- Claim Portal: 85% complete
- Mass Processing: 60% complete
- Review and Liquidation/Reliquidation: 80% complete
- Refund Functionality: 75% complete
In a March 31 update to the Court of International Trade, CBP indicated that Phase I of CAPE is expected to process refunds for approximately two-thirds of eligible claims. This includes entries that remain unliquidated or are within the 90-day voluntary reliquidation period.
Most importers of record already utilize the ACE system and remit payments electronically. If CAPE functions as intended, refunds may be processed automatically without additional action required. At this time, there is no confirmed timeline for when refunds will be issued, as key components of the CAPE system remain under development.
Importers should also be aware that any refunds received may be subject to claims from downstream buyers. Additionally, class action activity is beginning to emerge related to these tariffs.
We will continue to monitor this situation and provide updates as additional guidance becomes available. If you believe your organization may be impacted, please reach out to your WG advisor to discuss potential exposure and next steps.
