CBP IEEPA Refund Process Update: What Importers Need to Do Now (March 2026)

The IEEPA tariff refund process is moving — but it's moving in ways that demand importer action right now. In March 2026, CBP released updated guidance on the refund mechanics, ACE portal requirements, and ACH enrollment deadlines that every eligible importer needs to understand. If you paid IEEPA duties between April 2025 and February 2026 and haven't taken the steps outlined below, you risk significant delays in receiving your refund.

This post breaks down exactly what changed, what you need to do this month, and how to check your liquidation status so you know where you stand.

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What Changed in the CBP Refund Process

CBP's updated guidance, issued in coordination with the Court of International Trade (CIT), introduced several procedural changes that affect how and when importers will receive their IEEPA refunds:

1. Phased Refund Disbursement

CBP confirmed it will process refunds in three distinct phases rather than a single mass disbursement:

• Phase 1 (April–June 2026): Unliquidated entries where the importer has a verified ACE account and ACH enrollment. These are the simplest cases — CBP can reliquidate and refund automatically.
• Phase 2 (July–September 2026): Liquidated entries where the importer filed a timely protest. These require individual review and protest resolution before refund.
• Phase 3 (Q4 2026–2027): Complex cases including entries with prior discrepancies, ongoing audits, or disputed classification. These will be handled on a case-by-case basis.

The critical takeaway: if you want to be in Phase 1, you must have your ACE portal access and ACH enrollment completed before the CAPE module goes live in mid-April.

2. ACH Enrollment Is Now Mandatory for Electronic Refunds

Previously, CBP could issue paper refund checks. The updated guidance states that all CAPE-processed refunds will be disbursed via ACH (Automated Clearing House) only. Importers without ACH enrollment will not receive automated refunds — they'll be pushed to Phase 3 for manual processing, which could mean waiting until late 2026 or into 2027.

3. Consolidated Entry Review

CBP will consolidate all IEEPA-eligible entries per importer into a single refund calculation. This means you won't receive 50 separate refunds for 50 separate entries — you'll get one consolidated payment per phase. The upside is efficiency; the downside is that if any entry in your consolidated batch has a discrepancy, the entire batch could be held for review.

4. Broker Authorization Updates

If you use a customs broker, CBP now requires explicit broker authorization for CAPE refund processing. This is a new requirement — your existing broker power of attorney (POA) may not cover CAPE-specific actions. Check with your broker to confirm they've filed the updated authorization.

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What You Need to Do This Month

Here is your action checklist for March 2026. Every item on this list directly affects whether you're in Phase 1 (fast) or Phase 3 (slow).

Action 1: Verify Your ACE Portal Access

Log in to the ACE portal at ace.cbp.dhs.gov. If you can't log in, you need to:

1. Request an ACE portal account through CBP's Account Management team
2. Verify your importer of record (IOR) number is linked to your account
3. Confirm your company's identity through the ACE Secure Data Portal

Timeline: ACE account setup takes 5–10 business days. If you start now, you'll be ready before CAPE launches.

Action 2: Enroll in ACH for CBP Refunds

ACH enrollment for CBP refunds is done through the ACE portal under Account Management > Payment Settings > ACH Enrollment. You'll need:

• Your company's bank routing number and account number
• A voided check or bank letter confirming the account
• Authorization from a company officer (signatory authority)

Important: This is separate from any ACH enrollment you may have for paying duties. Refund ACH enrollment is a distinct process.

Action 3: Run a Liquidation Status Check

Not all of your IEEPA entries may be in the same liquidation state. You need to know which are unliquidated (Phase 1 eligible) and which have already liquidated (Phase 2).

Here's the decision tree:

Is the entry unliquidated?

• Yes → You're eligible for Phase 1 automated refund via CAPE
• No → Has the entry liquidated?
  • Yes → Did you file a protest within 180 days of liquidation?
    • Yes → You're eligible for Phase 2 protest-based refund
    • No → Is the protest deadline still open?
      • Yes → File a protest immediately to preserve your refund rights
      • No → You may need legal counsel to explore options (Phase 3 or litigation)

You can check liquidation status in ACE under Reports > Entry Summary > Liquidation Status. Look for entries with HTS codes that carried IEEPA duties during the eligible period.

Action 4: Reconcile Your IEEPA Duty Payments

Before CAPE calculates your refund, make sure your records match what CBP has on file. Pull your ACE entry summaries and cross-reference:

• Total IEEPA duties paid per entry
• The specific IEEPA rate applied (reciprocal, fentanyl, or both)
• Any partial payments, supplemental duties, or adjustments

Discrepancies between your records and CBP's will cause your entries to be flagged for manual review, bumping you to Phase 3.

Action 5: Update Your Broker Authorization

Contact your customs broker and confirm:

1. They have an active POA covering CAPE refund processing
2. They've registered for CAPE access on your behalf (if applicable)
3. They have your current ACH information for refund routing

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Understanding the Liquidation Status Decision Tree

The single most important factor in your refund timeline is liquidation status. Here's why it matters and how to interpret what you see in ACE.

What Is Liquidation?

Liquidation is CBP's final determination of the duties owed on an import entry. Until an entry is liquidated, the duty amount is provisional — it can be changed. After liquidation, the duty amount is fixed unless successfully protested.

Why It Matters for Refunds

• Unliquidated entries can be reliquidated by CBP automatically. CBP simply recalculates the entry without the IEEPA tariff component and issues the difference as a refund. This is Phase 1 — fast and automated.
• Liquidated entries have a fixed duty amount. To change it, you need a successful protest. CBP must review the protest, agree the IEEPA component should be removed, and then process the refund. This is Phase 2 — slower but still systematic.
• Liquidated entries with no protest are the most problematic. If the 180-day protest window has closed, your options narrow significantly.

Checking Liquidation Status in ACE

1. Log in to ACE at ace.cbp.dhs.gov
2. Navigate to Reports > Entry Summary Reports
3. Filter by date range: April 1, 2025 through February 24, 2026
4. Look for the Liquidation Status column
5. Export the results to CSV for your records

Status codes you'll see:

Status Code	Meaning	Refund Phase
OPN	Open / Unliquidated	Phase 1
LIQ	Liquidated	Phase 2 (if protested)
SUS	Suspended liquidation	Phase 1 (pending resolution)
REL	Reliquidated	Already processed

If you see SUS (suspended), this means CBP has intentionally held liquidation open — often specifically because of the IEEPA litigation. Suspended entries are generally good news for refund purposes.

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Estimated Refund Amounts by Tariff Program

Not sure how much you're owed? Here's a quick reference for the IEEPA tariff rates that were in effect:

IEEPA Program	Rate	Effective Dates	Countries Affected
Reciprocal tariffs (baseline)	10%	April 5–9, 2025	Most countries
Reciprocal tariffs (escalated)	11–50%	April 9, 2025 – Feb 24, 2026	Country-specific
Fentanyl tariffs	20%	Feb 4, 2025 – Feb 24, 2026	China
Fentanyl tariffs	25%	March 4, 2025 – Feb 24, 2026	Canada, Mexico

Stacking note: Many importers paid multiple IEEPA tariffs on the same goods. For example, Chinese imports often carried both the reciprocal tariff AND the fentanyl tariff, for a combined IEEPA rate of up to 70%. Your refund should cover all IEEPA components.

Use our Refund Estimator tool to calculate your specific refund amount based on your import volume and the applicable rates.

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Common Mistakes That Delay Refunds

Based on what we're seeing from early filers, here are the most common issues that push importers from Phase 1 to Phase 3:

1. Stale ACE Portal Credentials

Many importers set up ACE accounts years ago and haven't logged in since. If your account has been deactivated due to inactivity, you'll need to go through reactivation — which adds 5–10 business days.

2. Missing ACH Enrollment

This is the number-one issue. Even importers with active ACE accounts often don't have ACH set up for refunds. Don't assume your duty payment ACH covers refunds — it doesn't.

3. Unfiled Protests on Liquidated Entries

If your entries liquidated in late 2025 or early 2026 and you didn't file a protest, you may be running out of time. The 180-day protest window is a hard deadline. Check your liquidation dates and file protests before the window closes.

4. Broker POA Gaps

Your broker can't act on CAPE refunds without proper authorization. If you changed brokers during the IEEPA tariff period, make sure your current broker has complete authority.

5. Record Discrepancies

If your internal records don't match ACE entry summaries, CBP will flag your entries for manual review. Reconcile now, not after CAPE launches.

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What Happens After You've Completed These Steps

Once you've checked every box above, you're positioned for Phase 1 processing. Here's what to expect:

1. CAPE launches (mid-April 2026): You'll see a new module in your ACE dashboard
2. Automated entry review: CAPE consolidates your IEEPA entries and calculates the refund
3. Notification: You'll receive an electronic notice with the calculated refund amount
4. Disbursement: ACH payment within 10–15 business days of notice
5. Confirmation: Final reliquidation notice posted to your ACE account

If anything in your entries requires manual review, you'll receive a notice explaining what's needed and your estimated timeline.

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Track Your Refund Status

Don't wait in the dark. Use our Refund Status Tracker to monitor your IEEPA refund progress in real time. The tracker connects to CBP's systems and shows you:

• Which of your entries are unliquidated vs. liquidated
• Whether your protests have been received and logged
• Estimated refund amounts by entry
• Your position in the processing queue

Combined with our Refund Estimator, you'll have complete visibility into what you're owed and when you can expect to receive it.

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Next Steps

1. Today: Log in to ACE and verify your account is active
2. This week: Enroll in ACH for refunds and check your liquidation status
3. Before April 15: Confirm your broker has updated CAPE authorization
4. Ongoing: Monitor your refund status through our Refund Status Tracker

The CBP refund process is real and it's moving. But the importers who act now will get their money first. Don't wait for CAPE to launch to start preparing — the preparation window is closing.