In today’s volatile trade environment, importers are facing a perfect storm of regulatory complexity. Between the evolving landscape of IEEPA refunds and the latest adjustments to Section 232 tariffs on steel, aluminum, and copper, companies are being asked to stay agile, informed, compliant, and proactive all at once.
For many, the challenge is not just understanding one policy change. It is managing multiple, overlapping developments that directly impact cost, compliance, and supply chain strategy.
This article focuses on what importers need to know about IEEPA refunds and how to prepare.
The IEEPA Refund Opportunity and the Pressure That Comes With It
Refunds tied to the International Emergency Economic Powers Act (IEEPA) present a significant financial opportunity for importers. Companies that previously paid IEEPA duties may be eligible to recover substantial amounts.
However, uncertainty around the process has created concern.
Many importers are unsure how to proceed and worry about missing the opportunity altogether.
Recent updates from Customs and Border Protection (CBP) and the Court of International Trade (CIT) confirm that the process will require active participation.
CBP will issue refunds through its new Consolidated Administration and Processing of Entries (CAPE) tool within the ACE portal, and the rollout will occur in multiple phases.
Importers will need to identify impacted entries, organize data by liquidation status and entry type, ensure ACE access, and submit refund declarations once the CAPE portal opens.
For many compliance and logistics teams, this represents a significant operational lift.
Timing: What We Know About the CAPE Rollout
Recent communications from CBP and the CIT provide important clarity on timing.
CBP has indicated that development remains on schedule, although key functionality is still being finalized.
At the same time, the CIT has confirmed that CBP is expected to begin accepting Phase One refund applications on April 20.
Once filed, CBP estimates that refund claims may take approximately 45 days to process.
Following the CIT’s March 20 clarification that all IEEPA duties must be refunded regardless of liquidation status, CBP adjusted its approach.
The CAPE system will now roll out in phases, with only Phase One expected to be available initially.
This creates urgency. Importers should be prepared to file as soon as the portal opens.
Delays in filing could push eligible entries into later phases, extending the timeline for receiving refunds.
How the IEEPA Refund Process Will Work
CBP will begin accepting Phase One refund requests for specific types of entries, including:
- Unliquidated entries
- Entries within 80 days of liquidation at the time of filing
- Entries in suspended, extended, or under review status
- Warehouse entries and withdrawals (processed on the normal liquidation schedule)
- Certain AD/CVD entries, subject to standard processing timelines
It is important to note that:
- April 20 is an estimated launch date and may shift
- Entries with open protests will not be processed in Phase One
- Refunds may be delayed if there are outstanding Customs bills
Entries that fall outside of Phase One will be addressed in future phases. These include:
- Entries more than 80 days past liquidation
- Reconciliation entries and drawback claims
- Entries currently under protest
- Certain AD/CVD entries pending liquidation
Because of this phased approach, having accurate and well-organized data will be critical to maximizing recovery.
What Importers Should Do Now
With the April 20 deadline approaching, preparation is essential. Importers should take the following steps:
- Confirm access to the ACE portal
- Ensure ACH refund account setup is complete
- Export reports identifying all entries with IEEPA duties
- Segment entries by type, liquidation status, and protest status
- Identify which entries qualify for Phase One filing
In addition:
- Continue filing protests for entries approaching or exceeding the 90-day window
- Monitor updates from CBP regarding CAPE functionality and timelines
- Resolve any outstanding Customs bills that could delay refunds
- Coordinate with courier providers and suppliers regarding refund responsibilities
- Engage a trade compliance expert to review your data and filing strategy
The refund process will require careful coordination across teams and partners. Missing key details or deadlines could result in delayed or reduced recovery.
Common Questions About IEEPA Refund Filing
1.) What is IEEPA refund filing?
IEEPA refund filing is the process of submitting claims to recover duties previously paid under the International Emergency Economic Powers Act.
Importers must actively submit refund requests through CBP’s CAPE system within the ACE portal.
2.) When can importers begin filing for IEEPA refunds?
CBP has indicated that Phase One filings are expected to begin on April 20. However, timelines may shift, so importers should monitor updates and be prepared to file as soon as the portal opens.
3.) What entries are eligible for Phase One filing?
Phase One includes unliquidated entries, entries within 80 days of liquidation, and certain entries in suspended or review status. Other entries will be handled in future phases.
4.) How do importers submit IEEPA refund claims?
Refund claims are submitted through the CAPE tool in the ACE portal. CBP has indicated that filings will require uploading a CSV file of entry numbers, making it important to prepare accurate entry data in advance.
5.) Who can file an IEEPA refund and what is Form 4811?
Only the importer of record or the broker that originally filed the entry can submit an IEEPA refund claim through the CAPE system.
Form 4811 can be used to authorize another party to receive the refund, but it does not allow a different broker to file the claim if they did not originally file the entry.
If a different broker needs to be involved, updates may need to be made in ACE before filing.
6.) What happens if I do not have ACE access or ACH set up?
Importers without an active ACE account or ACH refund setup may not be able to participate in Phase One.
In these cases, refunds may be delayed or pushed to a later phase. Setting up ACE access and ACH authorization early is critical.
7.) Why am I having trouble accessing or updating my ACE account for IEEPA refund filing?
Some importers run into issues accessing their ACE account, especially if it was originally set up by someone who is no longer with the company.
Login credentials or verification steps may still be tied to that user. Companies can also get stuck updating CBP Form 5106 if it was previously filed by another party.
To avoid delays, confirm account access early, update user permissions, and ensure Form 5106 information is current.
8.) What happens if I miss Phase One?
Entries not filed during Phase One may need to wait for future phases of the refund process.
This could delay the timing of refunds, as CBP has not yet confirmed when later phases will be available.
9.) What documentation is required for IEEPA refund filing?
While the submission process may be simplified, importers still need accurate records of entries, including liquidation status and entry type.
Proper documentation ensures eligibility and helps avoid delays or rejections.
10.) How long will it take to receive a refund?
CBP has estimated that refund claims may take approximately 45 days to process after submission, although actual timelines may vary depending on volume and system readiness.
11.) What should importers do now to prepare?
Importers should ensure ACE access, confirm ACH refund setup, export and organize entry data, and identify which entries qualify for Phase One.
Early preparation will help maximize refund opportunities and reduce delays.
Get Ready for IEEPA Refund Filing
IEEPA refunds represent a meaningful opportunity to recover duties, but the process is structured, time-sensitive, and dependent on accurate data.
Importers that prepare early will be better positioned to capture refunds in the initial phase and avoid unnecessary delays.
Those that wait may find themselves pushed into later phases with less certainty around timing.
If you need support preparing your data, validating eligibility, or developing a filing strategy, get in touch with the Dimerco Trade Compliance team.
Our experts can help you move forward with confidence and ensure no opportunity is missed.
