Update to IEEPA refund process: Key implications for importers

US Customs and Border Protection (CBP) has now outlined initial plans for how the refunds may be administered in practice, including the development of a new system referred to as the Consolidated Administration and Processing of Entries (CAPE) to calculate and issue repayments. This represents a step towards a more structured and centralised refund process, although there is currently no confirmed timeline for processing the refunds.

The practical implications are still evolving. While CAPE is expected to cover certain unliquidated and non-final liquidated entries, it does not address entries that are liquidated and final.

Forvis Mazars US has issued an update summarising these developments and the potential implications, which may be a helpful reference point for understanding the emerging process and the recommended actions.

The recommended actions are below. 

• Electronic refund readiness: Confirm ACE Secure Data Portal access and ensure ACH refund authorisation and bank information are on file. The CBP’s webpage provides information on the ACE Portal and ACH Refunds FAQs.
• Data readiness: Importers may want to begin compiling entry summary identifiers and coordinating with their customs brokers (if applicable) to ensure portal access to support potential CSV-based submissions once CBP provides user guidance.
• Scope check: Identify whether affected entries may be excluded from initial CAPE functionality (e.g., entries with specified liquidation statuses or other complex entry types).
• Monitor developments: Watch additional CBP and Court updates that clarify timing, eligibility, and user instructions for submitting refund requests through CAPE.

We recommend that businesses affected should continue to keep the position under review and complete the actions suggested to safeguard potential refunds.