Recent developments regarding tariffs imposed under the International Emergency Economic Powers Act (IEEPA) may open doors for companies to recover duties they previously paid. These tariffs have now been invalidated, and companies that paid duties between 2025 and early 2026 are expected to qualify for refunds. Although the process is still being finalized, early indications suggest that refunds will be managed through the ACE system using a platform called CAPE, with payments likely to be issued electronically.
In preparation, companies may want to:
- Confirm access to an active ACE Secure Data Portal account
- Ensure CBP Form 5106 information is current
- Verify ACH refund authorization is set up correctly within ACE (separate from duty payment setup)
U.S. Customs and Border Protection is anticipated to provide further guidance on March 31 regarding the refund process, though timing of actual payments might occur later. Additionally, a 10% global tariff under Section 122 remains in effect, though USMCA-compliant goods — including most produce from Mexico and Canada — are exempt. Other trade actions may still be under review. Companies interested in obtaining refunds are encouraged to work closely with their customs broker or trade advisor.