What’s the difference between liquidated and unliquidated entries?

The distinction between liquidated and unliquidated entries is now central to refund strategy. Unliquidated entries are still open within CBP’s system, allowing duties to be corrected before finalization. Under the CIT’s direction, these entries should be liquidated without IEEPA tariffs, meaning importers may receive refunds through standard CBP processing. However, in practice, refunds may require submission of CAPE declarations through the importer’s ACE account to trigger the refund. Liquidated entries, by contrast, are considered final and can’t be adjusted through standard liquidation procedures. As a result, recovering duties on those entries requires additional steps, such as filing protests or participating in CBP-administered refund programs that haven’t been clearly defined yet.

What are replacement tariffs and why do they matter?

With IEEPA no longer available as a tariff authority, policymakers are turning to other trade remedy tools. This includes tariffs introduced under Section 122, which provide temporary authority and are subject to a defined timeline. Current Section 122 tariffs are limited to a 150-day window and are set to expire on July 24, 2026, and cannot be immediately reimposed under the same provision. At the same time, additional trade remedy actions under Section 301 and Section 232 are developing and expected. These replacement tariffs could create new compliance requirements and shift future duty exposure, making it important for importers to stay adaptable as the policy landscape evolves.

What tariffs are refundable?

Tariffs that may be eligible for refund generally include duties paid under IEEPA that were later determined to be unlawful, as well as overpayments resulting from the incorrect application of tariff provisions. It is equally important to understand what is not refundable in this context. This typically includes tariffs lawfully imposed under other authorities, such as: Section 301 tariffs for China-related trade remedies Section 232 tariffs on steel and aluminum Antidumping (AD) and countervailing duties (CVD) Other non-IEEPA trade remedies or statutory duties These categories are generally not impacted by the IEEPA ruling and are not eligible for refund through the CBP CAPE process tied to IEEPA recovery. Additionally, even within IEEPA-related entries, certain scenarios such as duty drawback, reconciliation filings or overlapping duty programs may require separate analysis and may not follow a straightforward refund path.

Are IEEPA tariffs automatically refundable?

IEEPA tariffs aren’t universally or immediately refundable, and treatment varies depending on entry status and entry type. Certain entry types, such as warehouse entries and warehouse withdrawals, are currently included in early phases of the CBP CAPE process, while others, including reconciliation entries, drawback claims, protested entries and AD/CVD entries, aren’t yet supported. For unliquidated entries, the CIT ruling effectively allows CBP to remove IEEPA duties during liquidation, which may result in refunds being issued through standard CBP processing. In practice, this may still require CAPE submissions, and importers must be set up for ACH with CBP to receive refund payments. For liquidated entries, however, refunds aren’t automatic. Importers must pursue recovery through formal administrative procedures, supported by documentation and subject to CBP review. In both cases, preparation and data accuracy remain critical.

What’s the ACE portal for U.S. Customs compliance?

The ACE portal is CBP’s primary system for managing import data and compliance activities. It allows importers to access entry records, monitor liquidation status and generate reports that are essential for identifying refund opportunities.

Why is ACE critical for tariff refunds?

ACE is required to pursue and receive IEEPA tariff refunds. Importers can’t access the CBP CAPE process without an ACE account, and refunds can’t be issued by CBP without both ACE access and ACH enrollment for electronic payment. Beyond access, ACE provides the data needed to distinguish between liquidated and unliquidated entries, calculate duties and validate claims. It also allows importers to monitor liquidation events, which is important given the CIT’s directive affecting unliquidated entries.

How to register for the CBP ACE portal?

Registering for the CBP ACE portal is a foundational step for managing compliance and preparing for any potential tariff refund activity. While the process is relatively straightforward, it does require coordination with CBP systems and, in some cases, your customs broker. The first step is ensuring that your company has a CBP Form 5106 (Importer Identity Form) on file. This form establishes or updates your importer profile with the CBP. If your company has been importing goods, a version of this form is likely already on file, but it’s worth confirming that the information, particularly contact details, is current. If updates are needed, they can be submitted through your broker or directly following CBP instructions. Once your importer record is established, you can apply for access to the ACE Secure Data Portal. This is done through the CBP ACE login page, where you will select the option to create a new account as an importer. The application requires basic company information, identification details and user credentials. CBP provides step-by-step instructions within the application. Most applicants find the process manageable if they have their company information readily available. After submitting the application, CBP will review the request and provision your account. Approval isn’t immediate. Due to volume and internal validation steps, it typically takes four to six weeks to receive access. Given the current surge in interest tied to IEEPA tariff refunds, delays are possible, so early registration is strongly recommended. Once your account is approved, you can log in to the ACE portal and verify that your company is correctly configured as an importer. This step is more important than it may seem. Users should confirm that the account reflects the correct importer of record, that access permissions are appropriate, and that key features, such as reporting capabilities, are available. If anything appears incorrect, it may require follow-up with the ACE help desk to resolve. Finally, take the extra step of configuring your account for practical use. This includes setting up contact information, assigning additional users if needed and critically enabling ACH refund functionality. Without ACH setup, CBP may not be able to disburse refunds even after claims are approved. Taking the time to complete these configurations upfront can prevent delays later when refund processes are fully implemented.

How to check if my imports face reciprocal tariffs?

To determine exposure, importers should analyze HTS classifications, review applicable tariff provisions and compare them against current trade measures. ACE data can help confirm whether tariffs have been applied and whether entries may be affected by policy changes.

Where can I find U.S. reciprocal tariffs list and HS classification guidance?

Official classification guidance and tariff schedules are available through government resources such as the Harmonized Tariff Schedule and CBP rulings. These sources provide the framework for determining tariff applicability and ensuring compliance.

What are the eligibility requirements for successful tariff refund claims?

To successfully recover duties, importers must demonstrate two eligibility requirements: Tariffs were paid under the invalidated IEEPA framework Amounts claimed are accurate and fully supported CBP is expected to review claims carefully, including classification, valuation and origin accuracy. Strong documentation and consistent data will be essential in both scenarios. For unliquidated entries, this primarily means ensuring that entry data is correct so CBP can process liquidation accurately. For liquidated entries, the burden is higher, requiring complete documentation and clear reconciliation between payments and claimed refunds.

How to identify shipments eligible for tariff refunds?

Identifying eligible shipments requires a structured review of import data. Begin by extracting entry-level information from the U. S. Customs ACE portal, focusing on entries that include IEEPA-related tariff codes. From there, duties paid should be evaluated against what should have been assessed. Equally important is determining whether each entry is liquidated or unliquidated. This distinction will dictate whether the refund is expected to occur automatically through liquidation or requires a formal claim.

What are the key eligibility timeframes and deadlines for filing a customs protest?

If an importer believes they’re owed an IEEPA tariff refund on liquidated entries, they can file a customs protest under 19 U.S.C. Section 1514 within 180 days of the liquidation date. Importers would file a CBP Form 19 protest, which is used to contest decisions, including: The amount of duties assessed The classification or valuation of goods The application of specific tariff provisions, including IEEPA-related duties For unliquidated entries, there’s no protest deadline in the same sense, but importers should monitor liquidation timing. Ensuring that entries are correctly classified and documented before liquidation occurs is critical because errors could affect the refund amount once CBP removes IEEPA duties.

How long do customs tariff refund claims take?

Refund timelines are expected to vary depending on the type of entry. For unliquidated entries, refunds may be processed more quickly as part of standard liquidation procedures. However, timing will still depend on CBP processing capacity. For liquidated entries, timelines are likely to be longer due to the volume of claims and the level of review required. Backlogs and extended review periods should be expected.

How to file a tariff refund claim with U.S. Customs?

While final procedures are still evolving, the expected process includes the following steps: Extract and validate entry data from ACE Reconcile duties paid versus duties owed to identify overpayments Prepare supporting documentation Submit claims through the CAPE module in the ACE portal Undergo CBP review and validation Receive refunds via ACH For unliquidated entries, this process may be limited to monitoring liquidation outcomes and ensuring data accuracy. For liquidated entries, full claim preparation, submission and follow-through will be required.

What documentation is needed to support tariff refund applications?

Supporting documentation should clearly connect each claimed refund amount to the original transaction. This includes entry summaries, payment records and commercial documentation, along with internally prepared calculations. Even for unliquidated entries, maintaining complete documentation is important. CBP may still review entries before issuing refunds, and discrepancies could delay or reduce recovery.

What tactical advice applies to post-summary corrections?

Post-summary corrections are one of the most practical tools importers have to improve the quality of their data before it’s reviewed by CBP or used to support a tariff refund claim. Given the heightened scrutiny expected around IEEPA-related entries, this isn’t just a cleanup exercise; it’s a risk management step. Start by conducting a targeted review of your entries, focusing on the areas CBP is most likely to examine. This includes tariff classification, declared value and country of origin. These elements directly affect duty calculations, and even small inconsistencies can lead to incorrect refund amounts or trigger additional questions from CBP. In the context of IEEPA, it’s especially important to confirm that the correct Chapter 99 provisions and duty rates were applied at the time of entry. Where discrepancies are identified, corrections should be made as early as possible, ideally before liquidation occurs. For unliquidated entries, this is particularly important because CBP will be recalculating duties as part of the liquidation process following the CIT’s directive. If the underlying data is incorrect, the resulting refund may also be incorrect. For entries that have already liquidated, corrections should be aligned with any protest filings or refund claims to ensure consistency. Consistency across filings is another critical factor. The data reflected in your ACE reports, internal systems, broker filings and supporting documentation should all tell the same story. Mismatches in quantities, values or classifications can slow down review or raise red flags. Taking the time to reconcile these data points upfront can significantly improve the efficiency of the claims process. Finally, documentation should be clear, organized and audit-ready. This means not only retaining required documents such as entry summaries and invoices, but also maintaining internal work papers that explain how corrections were identified and how revised calculations were determined. If CBP reviews your claim, they should be able to follow your logic without needing extensive clarification. In practice, companies that treat post-summary corrections as part of a structured review process, rather than a last-minute adjustment, are better positioned to support their claims and avoid delays once refund procedures are underway.

Should companies pursue litigation or administrative claims for tariff refunds?

The current direction favors administrative refund processes because the courts already resolved the core legal issue, IEEPA tariffs weren’t authorized. The remaining work is operational, not legal. CBP has been directed to implement refunds through established processes, particularly for unliquidated entries where liquidation adjustments can address overpayments. Litigation may still be relevant in certain cases, but for most importers, it’s unlikely to accelerate recovery. Administrative processes are expected to be the primary mechanism for both unliquidated and liquidated entries, with success driven by documentation and execution.

What are key tariff refund litigation considerations and deadlines?

For liquidated entries, the most important deadline is the 180-day protest period from the date of liquidation. Filing within this window preserves the importer’s right to challenge duty assessments and pursue refunds. For unliquidated entries, litigation is generally less relevant because the CIT has already directed CBP to remove IEEPA tariffs during liquidation. Instead, the focus should be on ensuring that entries are accurate before liquidation occurs.

What are common mistakes in refund preparation?

Many companies underestimate the complexity of refund preparation, assuming that eligibility alone guarantees recovery. In practice, incomplete documentation, inconsistent data and lack of internal validation are common issues that delay or derail claims. Companies that invest in thorough preparation and data integrity are better positioned to navigate CBP review successfully.

Where to find CBP IEEPA guidance for importers?

CBP guidance is expected through CSMS notices, regulatory updates and communications tied to Court of International Trade developments. Importers should monitor these sources closely as procedures for implementing refunds, particularly for liquidated entries, continue to evolve.

How to comply with IEEPA reciprocal trade restrictions?

Although IEEPA tariffs were invalidated, compliance obligations remain. Importers should ensure accurate classification, maintain complete documentation and stay aligned with any new measures introduced under the Reciprocal Tariff Act. The shift away from IEEPA doesn’t reduce scrutiny on trade compliance.

How to monitor policy changes under Reciprocal Tariff Act?

Monitoring policy changes requires ongoing attention to regulatory developments, including agency updates and legislative actions. Importers should establish processes to track changes, assess their impact and adjust compliance practices accordingly.

How does Baker Tilly support tariff refund readiness?

Baker Tilly’s tariff refund and recovery services help organizations move from legal ruling to operational execution. Our global trade advisors work alongside federal, state and international tax specialists, as well as data and technology teams, to assess refund exposure, organize and validate entry data, develop defensible calculation methodologies and establish governance frameworks aligned with anticipated CBP requirements. We bring deep industry knowledge across manufacturing, transportation and logistics, aerospace and defense, retail, private equity and other trade-intensive sectors. This perspective allows us to tailor refund strategy, documentation readiness and tax planning considerations to the operational realities of each organization. By prioritizing readiness before formal refund procedures are finalized, organizations can reduce execution risk and position themselves to act decisively when filing windows open. This integrated, industry-informed approach supports timely submission, clearer administrative review and stronger confidence throughout the recovery process.

Resource

IEEPA FAQ: Tariff refund rules, eligibility and filing steps

April 8, 2026 · Authored by Pete Mento, Tosca Derrick

Recent court rulings have upended tariff refunds tied to the International Emergency Economic Powers Act (IEEPA), a federal law that allows the president to impose trade restrictions during a declared national emergency. These developments create new opportunities for recovery while also introducing uncertainty, particularly around how U.S. Customs and Border Protection (CBP) will administer refunds.

Importers now face a fragmented process depending on their specific circumstances. Unliquidated entries generally have a more straightforward path, while entries that have already been liquidated may require a more complex route to recovery.

This IEEPA FAQ is designed to help importers understand how court rulings and evolving CBP processes affect their ability to pursue a tariff refund.

What’s the difference between liquidated and unliquidated entries?
What are replacement tariffs and why do they matter?
What tariffs are refundable?
Are IEEPA tariffs automatically refundable?
What’s the ACE portal for U.S. Customs compliance?
Why is ACE critical for tariff refunds?
How to register for the CBP ACE portal?
How to check if my imports face reciprocal tariffs?
Where can I find U.S. reciprocal tariffs list and HS classification guidance?
What are the eligibility requirements for successful tariff refund claims?
How to identify shipments eligible for tariff refunds?

Pete Mento

Director

Tosca Derrick

Director

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global trade

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How to use the ACE portal to gather data for IEEPA tariff refunds

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The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. Tax information, if any, contained in this communication was not intended or written to be used by any person for the purpose of avoiding penalties, nor should such information be construed as an opinion upon which any person may rely. The intended recipients of this communication and any attachments are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of this communication and any attachments.

IEEPA FAQ: Tariff refund rules, eligibility and filing steps

Pete Mento

Tosca Derrick

Related sections

Article Tags

How to use the ACE portal to gather data for IEEPA tariff refunds

Tags

What’s the difference between liquidated and unliquidated entries?

What are replacement tariffs and why do they matter?

What tariffs are refundable?

Are IEEPA tariffs automatically refundable?

What’s the ACE portal for U.S. Customs compliance?

Why is ACE critical for tariff refunds?

How to register for the CBP ACE portal?

How to check if my imports face reciprocal tariffs?

Where can I find U.S. reciprocal tariffs list and HS classification guidance?

What are the eligibility requirements for successful tariff refund claims?

How to identify shipments eligible for tariff refunds?

What are the key eligibility timeframes and deadlines for filing a customs protest?

How long do customs tariff refund claims take?

How to file a tariff refund claim with U.S. Customs?

What documentation is needed to support tariff refund applications?

What tactical advice applies to post-summary corrections?

Should companies pursue litigation or administrative claims for tariff refunds?

What are key tariff refund litigation considerations and deadlines?

What are common mistakes in refund preparation?

Where to find CBP IEEPA guidance for importers?

How to comply with IEEPA reciprocal trade restrictions?

How to monitor policy changes under Reciprocal Tariff Act?

How does Baker Tilly support tariff refund readiness?

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