CBP Advances Tariff Refund System Following March 12 Court Update

U.S. Customs and Border Protection (CBP) has begun implementing a new refund process for tariffs invalidated by the Supreme Court’s February ruling on the International Emergency Economic Powers Act (IEEPA), according to a March 12 status report filed with the U.S. Court of International Trade (CIT). The update indicates that refunds have not yet started, but system development is actively underway and progressing toward deployment.

CBP reported that key components of the refund system are between roughly 40% and 80% complete, with testing already underway for certain functions. The agency is building a new claims-based process within its Automated Commercial Environment (ACE) platform that will allow importers to request refunds on an importer-wide basis, rather than through millions of individual entry corrections. The approach is intended to streamline administration of what CBP has described as an unprecedented effort involving more than 330,000 importers and over $166 billion in duties.

The CIT has allowed CBP additional time to complete the system and has not required immediate repayment, while continuing to oversee progress through required status updates. The court has emphasized that refunds must ultimately be issued with interest, which continues to accrue at an estimated rate of approximately $650 million per month.

CBP has indicated that the refund process could become operational as early as mid-April, consistent with its earlier estimate of a roughly 45-day implementation timeline. Additional guidance is expected on submission procedures, validation requirements, and payment sequencing as the system nears completion.