Update on IEEPA Tariffs
18 March 2026
US Customs and Border Protection (CBP) has confirmed that it is not yet positioned to process refunds related to tariffs imposed under the International Emergency Economic Powers Act (IEEPA) following the recent court decision invalidating those duties. The agency is currently developing system enhancements within the Automated Commercial Environment (ACE) to support what is expected to be a large-scale refund process affecting a significant number of importers and entries.
CBP has indicated that the refund mechanism could be operational within approximately 45 days, pending additional procedural guidance and court direction. Once implemented, refunds are expected to be issued electronically through ACE via Automated Clearing House (ACH).
Given the scale and complexity of the potential refunds, importers should anticipate that the process may take time to fully administer once the system becomes available.
Key considerations for US importers
- CBP refund processing capability is currently under development within ACE.
- Refunds are expected to be distributed electronically via ACH through the ACE portal.
- Importers must ensure their ACE account access and banking details are properly configured to receive electronic refunds.
- Accurate entry data and supporting documentation may be required during the refund validation process.
Recommended Actions
- Importers should consider the following preparatory steps:
- Confirm ACE Portal access for the Importer of Record.
- Verify ACH refund enrollment within ACE.
- Identify entries where IEEPA tariffs were assessed and paid.
- Maintain supporting documentation, including entry summaries, invoices, and duty payment records.
We will continue to monitor developments closely and share updates as further clarification becomes available. For more information, please contact your local Toll Global Forwarding representative or email me at [email protected].
Keri Sanabria
Vice President Customs Brokerage North America
Toll Global Forwarding
Disclaimer: This material is for information purposes only and shall in no way be construed as legal advice. The matters addressed herein may be subject to further interpretation and rules that may be issued by regulatory authorities, changes to applicable law, and common law interpretation. No representation or warranty, express or implied, is made as to, and no reliance should be placed on, the fairness, accuracy, completeness or correctness of the information or opinions contained herein. Reliance on this material is at the user’s own risk. None of Toll nor any of its affiliates, advisors or representatives shall have any liability whatsoever (in negligence or otherwise) for any loss howsoever arising from any use of this material or its contents. This material shall not be reproduced, retransmitted or further distributed to any other person or entity, in whole or in part, for any purpose, except with prior written consent of Toll.



