Important: IEEPA Tariffs Refunds Updates w/ CBP ACE Resources)

MARCH 6, 2026 CBP Outlines Path to Processing IEEPA Refunds, ACE Work Underway – Not Yet Ready

According to the NCBFAA’s latest update, CBP told the Court of International Trade on March 6 that it is not yet ready to process court‑ordered IEEPA tariff refunds.The agency expects to update the ACE system within roughly 45 days to handle the refund process. CBP confirmed it must liquidate or reliquidate all affected entries without including IEEPA duties.A new ACE capability would allow refunds to be consolidated by importer, avoiding tens of millions of individual entry‑level payments.

The planned process includes:

  • The importer files a declaration in ACE that includes a list of entries on which IEEPA duties were paid.
  • ACE runs a series of validations on each entry within the declaration and automatically re-calculates the duty owed without the IEEPA tariffs (with applicable interest).
  • CBP verifies the declaration and processes refunds as soon as practicable.
  • ACE automatically finalizes (liquidates or reliquidates) the entries.
  • ACE automatically aggregates the refunds with interest by importer and liquidation date.
  • CBP certifies the refunds.
  • The Department of the Treasury issues IEEPA refunds electronically.”

CBP indicated that completing all refunds for all importers may take several months or longer.

MARCH 4, 2026 CIT Ordered U.S. Government to liquidate or re-liquidate entries without IEEPA Duties

On March 4, 2026, the Court of International Trade (CIT) ordered the U.S. Government to liquidate or re-liquidate entries without IEEPA duties and refund all IEEPA duties collected from importers.

The presiding judge emphasized that CBP must refund all IEEPA duties, regardless of whether an importer is part of the current litigation.

The order will likely not be immediately effective: The Government is expected to appeal to the U.S. Court of Appeals for the Federal Circuit and request a stay, which would pause the CIT’s order.

Recommended Importer Actions:

  • Contact a trade attorney and file CIT actions immediately to protect refund rights.
  • Protest any entries with IEEPA duties within 180 days of liquidation to maintain eligibility for refunds.
  • Ensure ACE accounts are properly set up to receive electronic refunds/communications from CBP.

In case you have not received our previous e-blasts about CBP’s mandatory transition to electronic refunds, here are some important resources from CBP if you would like to know the steps on how to set up an ACE Portal Account. 

It is important that you set up an ACE Portal account with CBP. You will not get any refunds if you do not add your ACH banking details to ACE Portal. 

If you are a foreign importer of record, you will still need to create an ACE Portal account and add a U.S. notify party. 

RESOURCES to CBP ELECRONIC REFUNDS and ACE REPORTS

  • To access CBP’s Electronic Refund Enrollment Reference Sheet, please click on this link.
  • For those who do not currently have ACE Portal account access, use the new automated application to create a top account with the importer sub-account view – please click on this link
  • If you get an error when you submit your application, you must have a current CBP Form 5106 record on file with CBP to access the Importer sub-account view. Please submit this form to Flegenheimer with a valid email address. We will then update your records with CBP. Once this is updated you may complete your ACE Portal application. 

Once you have an ACE Portal Account, you can run a report for all entries that are liquidated and unliquidated, please go to:

ACE Training and Reference Guides

ACE Refund Report: https://www.cbp.gov/sites/default/files/2025-10/ace_reports_trade_refund_report_qrc.pdf

For more information:

https://www.cbp.gov/trade/automated/how-to-use-ace/portal-applying

For General Questions Email:
ACEPortalModHelp@cbp.dhs.gov

For Technical Issues:
Phone: 866-530-4172
Email: ACE.Support@cbp.dhs.gov

Please go to our website to check the latest information on IEEPA Tariff Refund and see the latest news: 

https://flegenheimer.com

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