U.S. Customs and Border Protection (CBP) has launched the first phase of the newly created Consolidated Administration and Processing of Entries (CAPE) system to process refunds for certain International Emergency Economic Powers Act (IEEPA) duties that were ruled illegal by the U.S. Supreme Court earlier this year. For eligible importers of record and authorized customs brokers who successfully navigate the CAPE system, this may create a significant opportunity to efficiently recover tariff payments and interest. However, because of the volume and complexity of potential claims, importers should begin evaluating eligibility and documentation needs as soon as possible. The process requires accurate entry-level data, complete documentation and careful coordination across customs, tax, finance and compliance teams.
Phase I of the CAPE Tariff Refund Process
CBP launched Phase 1 of the CAPE system on April 20, 2026. Phase 1 currently applies to certain unliquidated entries and entries liquidated within approximately 80 days of filing. This first round of IEEPA tariff refund claims must be electronically submitted through the CBP ACE Portal in the required format. Importers should also confirm they have ACE Portal access and the appropriate banking information on file to receive potential refunds.
The refund process is expected to involve a significant volume of claims relating to the estimated $166 billion in IEEPA tariffs paid. As a result, companies may face processing delays. Incomplete documentation, inconsistent data or unsupported filings will increase the likelihood of error codes, technical delays, denials or additional CBP scrutiny.
Key Risks to Consider Before Filing Tariff Refund Claims
Although tariff refunds may represent a meaningful financial opportunity, importers and authorized customs brokers should carefully assess the risks before filing. CBP may use refund claims as an opportunity to review customs compliance more broadly, including valuation, classification and country-of-origin determinations.
For many importers, this is not simply a customs exercise. The timing and the tax and accounting treatment of the refund may affect cash flow planning, financial reporting, tax positions, supplier relationships and broader compliance risk. Multinational companies may also be faced with customs related reviews or tax audits that may raise questions involving transfer pricing and other tax matters. Thus, it is important to evaluate claim data not only from a customs perspective, but also through a broader tax and accounting lens.
Vendor and Supplier Considerations
Not every company affected by tariffs was the importer of record. In some cases, vendors or suppliers may have paid the tariff and passed that cost along through pricing. If those vendors or suppliers are eligible for refunds, customers may need to evaluate whether they have a contractual or commercial basis to recover some of those amounts.
Affected companies may also need to consider whether sales tax was calculated on a higher taxable base because tariff costs were included in the purchase price. In those situations, tariff refunds may create related sales tax refund opportunities that require separate analysis.
How CBIZ Can Help
CBIZ can help companies assess potential tariff refund opportunities and navigate the related tax, accounting and compliance considerations. Our team can assist with:
- Reviewing import data to help identify potentially eligible entries
- Evaluating refund claim data for accuracy and completeness
- Assessing documentation requirements before claims are submitted
- Coordinating with customs brokers and other parties involved in the claim process
- Evaluating potential transfer pricing, refund tax treatment and accounting implications
- Assisting with vendor and supplier discussions when tariff costs were passed through in pricing
- Identifying potential related sales tax refund opportunities that may be available when tariffs increased the taxable base of purchased goods
With significant dollars potentially at stake, importers should take a thoughtful, well-documented approach to the tariff refund process.
To discuss how the tariff refund process may affect your business and what steps you should take next, connect with CBIZ today.
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