After months of uncertainty, the tariff refund process is finally live. U.S. Customs and Border Protection (CBP) has opened the first phase of its refund program through the ACE portal, giving companies that paid tariffs under IEEPA a clear path to recover funds.
There’s real money at stake. Estimates suggest tens of billions of dollars could be returned to importers, but accessing those refunds will depend on preparation, documentation, and careful execution.
The process is manageable, but it’s not automatic. Companies need to take a structured approach, especially in this first phase, where eligibility is limited. Below is a practical checklist to help you move forward.
1. Identify all entries where IEEPA tariffs were paid
Start with the basics. You need a complete view of every shipment that was subject to IEEPA tariffs.
For many companies, this information isn’t sitting in one place. It may live across internal systems, broker records, and data stored in the ACE portal. One of the most important documents to review is CBP Form 7501, also known as the Entry Summary.
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This form is filed with the CPB for every imported shipment. It includes key details such as the importer of record, product classification, declared value, and the duties and tariffs that were paid at the time of entry. In other words, it’s the official record of what you imported and what you paid to bring it into the country.
You’ll want to pull these forms, review your import records/ACE reports, and confirm that your organization was listed as the importer of record for each entry. That matters because only the party that imported can claim the refund.
This step sounds straightforward, but it can get complicated quickly. Tariff costs were often absorbed into inventory or spread across products over time, making it more difficult to trace them back to specific entries.
The goal here is to build a clean, defensible list of affected entries before you move on.
2. Determine which entries qualify for Phase 1
Not every tariff payment is eligible yet. CBP is starting with a narrower group of claims.
Right now, Phase 1 applies to two categories:
- Entries that are still unliquidated
- Entries that were liquidated within the past 80 days
Liquidation is the point when CBP finalizes an entry. That means they’ve reviewed the shipment and officially confirmed the duties and tariffs owed. Once an entry is liquidated, the amount paid is considered final. Unliquidated entries are still open, so the final duty amount hasn’t been locked in yet.
You’ll need to confirm the status of each entry using ACE reports or by working with your customs broker. Expect a mix. Some entries will qualify now, while others will need to wait for later phases.
Also, keep in mind that even if an entry falls within the timeline, it may still be excluded if it’s under review, suspended, or subject to other CBP processes such as duty drawback.
3. Gather and organize supporting documentation
Documentation will make or break your claim.
At a minimum, you should be pulling:
- CBP entry forms and ACE reports: Your official import records, which show what was filed with Customs and the duties paid for each shipment.
- Commercial invoices and certificates of origin: Invoices show what you bought and declared at import. Certificates of origin confirm the country of origin of goods, which affects tariff treatment.
- HTS classification support: The backup for how your products were categorized. Each product is assigned a code that determines the tariff rate.
- Payment records tied to each entry: Proof that the tariffs were paid, and by your company.
You may also need to go further. If tariff costs were passed through to customers or built into pricing, contracts and sales agreements could come into play. Some businesses will need to determine whether refunds should be shared based on those terms.
This is where preparation matters. The more clearly you can connect tariff payments to specific entries and supporting records, the smoother the filing process will be.
4. Confirm ACE access and payment setup
Before filing anything, make sure your systems are ready.
You’ll need active access to the ACE portal, either directly or through your customs broker. If multiple brokers were used, confirm visibility across all of them so nothing falls through the cracks.
Equally important, verify your ACH payment details. Refunds will be issued electronically, and missing or outdated banking information can delay the process.
It’s a simple step, but one that can hold things up if overlooked.
5. Prepare and review CAPE filing data carefully
Refund claims in this phase are submitted through CAPE using CSV files. Each file can contain thousands of entries, making accuracy critical.
Before submitting, review file formatting and data fields closely. Errors can lead to rejection, and with a high volume of claims expected, resubmissions could take time.
Once filed, monitor the status. A successful submission should receive confirmation in the system. If it doesn’t, you’ll need to troubleshoot quickly.
Building an internal review process with clear ownership can help avoid mistakes at this stage.
6. Submit claims and track progress in ACE
After submission, your job isn’t done.
Use ACE reporting tools to track acceptance, monitor claim status, and confirm when refunds are issued. CBP has indicated that payments for eligible claims may take 60 to 90 days, but early filings could face delays as the system ramps up.
You should also reconcile incoming payments against your original claims to ensure completeness.
Keeping a running tracker of all submissions, statuses, and payments will help you stay organized, especially if you’re filing multiple batches.
7. Consider financial and operational implications
Processing the refunds themselves will be a heavy lift, but there are implications beyond accessing the money. The refunds will impact your company’s finances and operations in several ways.
You may need to evaluate how recovered tariffs affect prior accounting treatments, inventory valuations, or tax positions. Timing differences can also create challenges, since tariff costs were recognized over time, but refunds may arrive in lump sums.
These questions don’t need to be fully resolved before filing, but they shouldn’t be ignored.
Moving forward
This first phase is only the beginning. CBP is starting with simpler cases and plans to expand the program to more complex scenarios later this year.
That means two things. First, there’s an opportunity to recover funds now for eligible entries. Second, there’s still work ahead for the rest of your claims.
Companies that get organized early, build clean data sets, and establish a repeatable process will be in a stronger position as additional phases roll out.
If the process feels heavy, you’re not alone. Many organizations are working through the same challenges. The key is to start with what you can control and move step by step.
Bryan Graiff is the Midwest industry leader and manufacturing and distribution leader and Nghi Huynh is the partner-in-charge of transfer pricing at Armanino, one of the largest accounting, consulting and technology firms in the U.S.
