Tariff Updates

CBP Preparing ACE Updates for IEEPA Tariff Refunds, but Processing Not Yet Ready

March 9, 2026

 On March 6, Customs and Border Protection (CBP) informed the Court of International Trade (CIT) that it is not yet able to process the court‑mandated refunds of IEEPA‑related tariffs. However, the agency noted that ACE programming necessary to carry out the refunds could be completed within approximately 45 days.

According to the filing, signed by Brandon Lord, Executive Director of the CBP Office of Trade, the agency is required to “liquidate any and all unliquidated entries subject to IEEPA duties without regard to those duties, and reliquidate any liquidated but non‑final entries in the same manner.”

Lord also stated that CBP expects to build new ACE functionality that will allow refunds—including interest—to be consolidated by importer, rather than issuing over 53 million individual entry‑specific refunds. This consolidation is intended to make the refund process significantly more efficient.

CBP outlined a tentative workflow for the new ACE process, noting that operational, legal, and technical factors may still require adjustments. The anticipated steps include:

1. Importers submitting an ACE declaration listing entries on which IEEPA duties were paid.
2. ACE performing validations and automatically recalculating duties excluding IEEPA tariffs (plus applicable interest).
3. CBP reviewing and processing refunds as quickly as feasible.
4. ACE automatically finalizing (liquidating or reliquidating) the entries.
5. ACE aggregating refund amounts and interest by importer and liquidation date.
6. CBP certifying the refund totals.
7. The Department of the Treasury issuing the refunds electronically.

While CBP is moving forward with preparations, the declaration suggests that completing refunds for all impacted importers could take several months or more.

This follows the CIT’s March 4 order directing CBP to liquidate unliquidated entries without IEEPA duties and to reliquidate eligible previously liquidated entries.

Averitt is monitoring this situation very closely, and as soon as CBP issues guidance on any actions required from importers, we will reach out directly to those affected to ensure everything is properly addressed.

At this time, you need to do the following in preparation:

• Confirm you have your ACE portal set up and it is accessible
• Ensure you are set up with CBP for ACH Refunds

For more information on your ACE portal, please visit CBP Modernizes Electronic Refund Enrollment Process