CBP is developing new functionality within the Automated Commercial Environment (ACE) to calculate and issue refunds for an estimated $165 billion in IEEPA tariffs collected before the U.S. Supreme Court invalidated global tariffs on February 20 in Learning Resources, Inc. et al. v. Trump. For trade compliance engineering teams managing rate calculations and duty estimations, this represents a significant system change requiring attention.

The Court of International Trade case Atmus Filtration, Inc. v. U.S. moved the refund process forward on March 6, when the court ordered CBP to report on progress toward developing refund procedures. In declarations filed in that case, CBP officials described internal development efforts under the Consolidated Administration and Processing of Entries (CAPE) module within ACE. Teams integrating with CBP systems or maintaining duty calculation engines should monitor for schema updates and new transaction types related to refund processing.

Standing Requirement: Under 28 U.S.C. § 1581(i), only importers of record have legal standing to file refund claims with the CIT. Downstream buyers who absorbed passed-through tariff costs cannot file directly—they must coordinate with their importers of record now to protect their interests in refund allocations.

The Learning Resources decision struck down IEEPA-based tariffs that had driven average U.S. import tariff rates from approximately 2.6% to 13% since 2025. The same day the Supreme Court ruled, Presidential Proclamation 11012 imposed a replacement worldwide 10% surcharge with a 15% cap, operating under a 150-day statutory limit. That limit expires at 12:01 a.m. on July 24 unless Congress extends it—a hard deadline that compliance systems must account for.

Rate Expiration Alert: The 10% surcharge from Proclamation 11012 has a fixed expiration of July 24. Systems caching this rate should implement expiration logic or flag entries for review before that date.

The administration continues pursuing alternative tariff authority through Sections 232 and 301 of the Trade Expansion Act of 1962, plus Section 338 of the Tariff Act of 1930. Section 338 authorizes duties up to 50% on imports from discriminating countries and has no meaningful prior use history—meaning classification systems have no historical precedent for how these duties would be structured or applied to HTS codes. Targets reportedly include China, the European Union, and other major trading partners, with tariffs potentially in place by summer.

For teams maintaining HTS rate databases, the current environment requires exceptional vigilance. The combination of the July 24 Proclamation 11012 expiration, pending Section 338 implementations without precedent, and the upcoming ACE refund functionality creates multiple vectors for rate data staleness. Nightly synchronization with authoritative sources is no longer optional—it's essential for accurate duty calculations.

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