Refund programming is coming, but full processing may take months.

On March 6, U.S. Customs and Border Protection (CBP) informed the Court of International Trade (CIT) that it is not yet prepared to process the court‑ordered refunds of IEEPA‑related tariffs. CBP stated it expects to have the necessary ACE programming in place within approximately 45 days.

In its filing, CBP confirmed that all unliquidated entries subject to IEEPA duties must be liquidated without those duties, and any liquidated but non‑final entries must be reliquidated accordingly. The filing, signed by Brandon Lord, Executive Director of the CBP Office of Trade, notes that CBP is developing new ACE functionality to consolidate refunds and interest by importer, avoiding the need to issue more than 53 million separate entry‑level refunds.

Under CBP’s proposed process, importers would submit a declaration in ACE listing entries with IEEPA duties, after which ACE would validate entries, recalculate duties and interest, liquidate or reliquidate automatically, and aggregate refund amounts before Treasury issues payments. Because this process depends heavily on ACE, importers with active ACE accounts, and particularly ACE Refunds accounts, will be better positioned to receive refunds quickly if CBP adopts this approach.

CBP indicated that completing refunds for all affected importers could take months once the system is operational.

On March 4, the CIT ordered CBP to liquidate all unliquidated entries without IEEPA duties and to reliquidate any liquidated but not‑yet‑final entries.

Deringer Customers: Get Started with Electronic Refunds Here

To let us know how we may best assist you, please complete our client form for IEEPA protests and electronic refunds. Go to the Form

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.