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Unlocking IEEPA Refunds: Essential Steps for Manufacturers

Update Understanding IEEPA Refunds: A Game Changer for ImportersAs of April 20, 2026, importers can breathe a sigh of relief as U.S. Customs and Border Protection (CBP) has finally rolled out the first phase of the Consolidated Administration and Processing of Entries (CAPE) system for filing refunds related to the International Emergency Economic Powers Act (IEEPA). For manufacturers heavily impacted by unlawful tariffs, this development opens the door to recovering billions of dollars in duties.Navigating the CAPE System: Key Steps for ImportersThe CAPE system streamlines the refund process through the Automated Commercial Environment (ACE) portal, designed specifically to handle the volume of refund requests and make the filing process as efficient as possible. To participate, manufacturers must first ensure that they are the Importer of Record (IOR) for the goods in question. If your goods were shipped through a carrier such as DHL or FedEx, contact them to verify whether they will file on your behalf.Importers also need to establish an ACE account, if they haven’t already done so. This account is essential not just for filing CAPE submissions but also for receiving refunds electronically through the Automated Clearing House (ACH)—a critical update, as traditional paper checks will not be issued. Once your ACE account is set up, it’s important to ensure you’re registered to receive ACH payments, providing your bank information to guarantee the swift arrival of your refunds.Eligibility Criteria: Are You Ready to File?For Phase 1 submissions, only certain types of entries are eligible. These include:Unliquidated entriesEntries liquidated within the prior 80 daysHowever, do keep in mind that entries flagged for reconciliation, entries with open protests, and entries subjected to antidumping/countervailing duties are currently excluded. If you attempt to submit an entry that does not meet these criteria, your entire CAPE submission may be rejected, leading to significant delays in your refund process.The Importance of Timely ActionTime is of the essence during this refund phase. CBP expects the processing of refunds may take between 70 to 100 days after your CAPE Declaration is accepted. Therefore, manufacturers should quickly assess their entry documentation, identify eligible entries, and compile necessary data for submission. Moreover, keeping abreast of potential revisions to the eligibility criteria in future phases is crucial for ensuring that you are not missing out on recovering additional funds.Maximizing Your Refund OpportunitiesFinancial recovery through IEEPA refunds represents a significant opportunity for manufacturers that faced undue financial strain from these tariffs. Understand not just how to file, but also the broader implications of these changes. Notably, you may need to adjust your business strategies in light of impending developments surrounding tariff policies that remain in flux.For those looking to stay updated, consider scheduling a session with trade experts or participating in webinars focused on these regulatory changes, like the one hosted by Holland & Knight, titled "CAPE Is Here: Now What?" Prospective speakers can provide insights that will help you navigate this complex landscape effectively.Conclusion: Take Action Now!The successful navigation of IEEPA refunds under the new CAPE system can greatly benefit your business. To make sure you are prepared, confirm your ACE account access, register for ACH refunds, and evaluate the eligibility of your entries. The road to recouping these duties might not be without challenges, but with the right strategies, the rewards can be substantial. Don't miss this chance to reclaim what is rightfully yours in the complex world of trade compliance.