IEEPA Duty Refund
What You Should Do Right Now
U.S. Customs and Border Protection (CBP) has established April 20 as the day importers can begin to apply for refunds on duties unlawfully collected under the International Emergency Economic Powers Act (IEEPA).
Check out the video below to understand more about the refund process.
Imported goods assessed duties under IEEPA are eligible for a refund. Once you submit your entries and they are validated, CBP estimates a 60- to 90-day refund process. There will be interest added to your IEEPA duty refund of about 6%.
The online refund process will be managed within a newly created system in CBP's ACE portal. It can be a little tricky if you don’t submit the exact right data in the right format. CBP created this handy reference guide to walk you through the steps. If you would like more personal guidance, Dimerco’s trade compliance experts can help assess your refund opportunity, compile your entries, and file on your behalf.
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Common Questions About IEEPA Refund Filing
1.) What is an IEEPA refund filing?
An IEEPA refund filing is the process of submitting claims to recover duties previously paid under the International Emergency Economic Powers Act. Importers must actively submit refund requests through CBP’s CAPE system within the ACE portal.
2.) When can importers begin filing for IEEPA refunds?
CBP has indicated that Phase One filings will begin on April 20.
3.) What entries are eligible for Phase One filing?
Phase One includes unliquidated entries, entries within 80 days of liquidation, and certain entries in suspended or review status. Other entries will be handled in future phases.
4.) How do importers submit IEEPA refund claims?
Refund claims are submitted through the CAPE tool in the ACE portal. CBP has indicated that filings will require uploading a CSV file of entry numbers, making it important to prepare accurate entry data in advance.
5.) Who can file an IEEPA refund and what is Form 4811?
Only the importer of record or the broker that originally filed the entry can submit an IEEPA refund claim through the CAPE system. Form 4811 can be used to authorize another party to receive the refund, but it does not allow a different broker to file the claim if they did not originally file the entry. If a different broker needs to be involved, updates may need to be made in ACE before filing.
6.) What happens if I do not have ACE access or ACH set up?
Importers without an active ACE account or ACH refund setup may not be able to participate in Phase One. In these cases, refunds may be delayed or pushed to a later phase. Setting up a free ACE account and ACH authorization early is critical.
7.) Why am I having trouble accessing or updating my ACE account for IEEPA refund filing?
Some importers run into issues accessing their ACE account, especially if it was originally set up by someone who is no longer with the company. Login credentials or verification steps may still be tied to that user. Companies can also get stuck updating CBP Form 5106 if it was previously filed by another party. To avoid delays, confirm account access early, update user permissions, and ensure Form 5106 information is current.
8.) What happens if I miss Phase One?
Entries not filed during Phase One may need to wait for future phases of the refund process. This could delay the timing of refunds, as CBP has not yet confirmed when later phases will be available.
9.) What documentation is required for IEEPA refund filing?
Importers need accurate records of entries, including liquidation status and entry type. Proper documentation ensures eligibility and helps avoid delays or rejections.
10.) How long will it take to receive a refund?
CBP has estimated that refund claims will take 60 – 90 days after the submitted entry is validated.
11.) What should importers do now to prepare?
Importers should ensure ACE access, confirm ACH refund setup, export and organize entry data, and identify which entries qualify for Phase One. Early preparation will help maximize refund opportunities and reduce delays.