As of March 4, 2026, approximately 53 million customs entries subject to IEEPA tariffs—representing $166 billion in deposits—await a refund mechanism that CBP says it cannot yet deliver. The agency filed Friday that it targets a 45-day implementation timeline to build an ACE-based process for returning duties on tariffs the Supreme Court deemed illegal in February.
The technical constraints are significant. ACE automatically liquidates entries every Friday morning, and CBP reported that 339,000 IEEPA-affected entries were scheduled for liquidation on March 6 alone. Liquidation locks in tariff amounts roughly 300 days after entry, meaning any entry that liquidates before the refund process goes live creates additional recovery complexity for importers.
Key Timeline: CBP ceased paper-based refunds in February 2026. Since then, 7,700 refunds have stalled because importers haven't registered for electronic refund processing. If your systems track refund eligibility, flag clients who may need to complete ACE electronic registration before the new mechanism launches.
Under CBP's proposed workflow, importers must submit entries via ACE for validation and recalculation. The system would strip IEEPA levies and recalculate amounts owed, but CBP personnel must still verify and certify each refund. ACE would then aggregate total refund amounts by importer and liquidation date. CBP estimates this manual verification requirement translates to over 4 million labor hours across all IEEPA-affected entries.
Integration Alert: CBP cannot quickly isolate IEEPA-affected entries within ACE because many importers calculate total duty by combining all applicable levies—including non-IEEPA tariffs that remain in force. Systems that cache duty rates or generate landed cost estimates should ensure IEEPA components are tracked as discrete line items, not rolled into aggregate duty fields.
The 300-day liquidation window creates an urgent data hygiene issue. Trade compliance platforms need to surface entries approaching liquidation deadlines so importers can pursue extensions or prioritize refund submissions once the ACE mechanism activates. Entries that liquidate with IEEPA duties intact aren't necessarily unrecoverable, but the process becomes significantly more manual.
CBP stated it cannot reprogram ACE quickly enough to halt scheduled liquidations or efficiently filter entries by tariff type. The agency's Friday filing noted that stopping liquidation would require either manual date extensions on individual entries or a system-wide halt to all scheduled liquidations—neither of which CBP considers viable at current operational capacity.
For engineering teams maintaining HTS-based duty calculation engines, the IEEPA refund saga underscores why tariff type metadata matters. Rate tables that distinguish between Section 301, Section 232, and IEEPA duties allow downstream systems to identify refund-eligible entries programmatically rather than relying on manual review. As CBP builds its validation layer, expect ACE submission formats to require explicit tariff categorization.
The 45-day target puts the earliest possible refund processing around mid-April 2026, assuming no court intervention alters the timeline. International trade partner James Kim of ArentFox Schiff noted Friday that much depends on how the Court of International Trade responds to CBP's stated inability to comply with its refund order.
TradeFacts.io delivers HTS and Canadian Customs Tariff data via JSON API, enabling compliance teams to build systems that track tariff types, liquidation windows, and rate changes programmatically—visit /contact.html to start a free 30-day trial.