CBP Preparing for IEEPA Refunds
Trade Update • March 6, 2026
Key Points
- On March 6, U.S. Customs and Border Protection informed the U.S. Court of International Trade that ACE updates are being developed for IEEPA duty refunds.
- The new ACE functionality may be operational within 45 days.
- The system will help process refunds for over 53 million entries.
- CBP has proposed a tentative workflow for processing applicable IEEPA refunds.
- The refunds follow a ruling by the Supreme Court of the United States that IEEPA does not authorize tariffs.
On March 6, U.S. Customs and Border Protection (CBP) informed (in a filing) the Court of International Trade (CIT) that development is underway to enable the Automated Commercial Environment (ACE) for IEEPA-related duty refunds.
CBP has indicated that this new ACE functionality may be operational in forty-five (45) days.
ACE Enhancement
This enhancement is intended to create an efficient, automated method for reviewing and processing more than 53 million entries that qualify for duty refunds following the recent Supreme Court (SCOTUS) decision.
CBP Workflow
The process may evolve as CBP considers operational, legal, and technical requirements, CBP’s initial proposed workflow is as follows:
- Importers submit an ACE declaration listing all entries on which IEEPA duties were paid.
- ACE performs automated validations on each listed entry and recalculates duties owed without the IEEPA tariffs, including applicable interest.
- CBP reviews and verifies the importer’s declaration and processes refunds as soon as practicable.
- ACE automatically liquidates or reliquidates all affected entries.
- ACE aggregates refund amounts, including interest, by importer and liquidation date.
- CBP certifies the refunds.
- The Department of the Treasury issues the refunds electronically.
At this time, no official guidance has been published. GHY will continue to monitor developments and provide updates as soon as additional information becomes available.
What Importers Can Do Now
GHY urges importers to start preparing/organizing their entry data now to ensure readiness for action once CBP issues official guidance.
Background
The ruling follows the February decision by the U.S. Supreme Court concluding that IEEPA does not authorize tariff measures. The appellate court recently issued its mandate, returning refund-related proceedings to the trade court. The March 4 order represents the first broad directive to CBP regarding liquidation and reliquidation of affected entries.
How GHY Can Help?
GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.
By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.
Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.
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