Over 55,000 parties submitted claims covering more than 4 million imports on the first day of CBP's IEEPA tariff refund system launch on Monday, according to CBP Executive Assistant Commissioner Susan S. Thomas. The volume signals the scale of refund liability that trade compliance teams are now tracking across their entry databases.
The refund system targets duties paid under now-defunct International Emergency Economic Powers Act tariffs. CBP structured the rollout in phases, with Phase 1 specifically covering entries liquidated within the previous 80 days of the system launch. This 80-day liquidation window creates a hard eligibility boundary that compliance engineering teams must query against their entry records to determine which shipments qualify for immediate filing.
Once an entry is submitted and accepted into the system, CBP's stated processing timeline runs 60-90 days before refund issuance. For systems that track duty liability and cash flow projections, this timeline introduces a significant lag between claim submission and actual fund recovery. Rate caching logic that still references defunct IEEPA rates will need conditional flags to handle pending refund status on historical entries.
The distinction between broker-filed and direct importer claims determines the filing pathway. Customers who served as importer of record can file directly through CBP or through an authorized representative. For entries where a carrier acted as customs broker, the carrier handles the filing.
FedEx committed to submitting refund declarations to CBP on behalf of all customers for whom it served as customs broker. UPS stated it will request and retrieve IEEPA tariff refunds from CBP for shipments where UPS was the importer of record. Both carriers confirmed they cannot issue refunds to customers until they receive funds from CBP—meaning the 60-90 day CBP processing window is the minimum wait time before any downstream disbursement.
DHL Express will automatically file refund claims for eligible entries covered by Phase 1. For shipments where a DHL customer served as importer of record, the customer retains the option to initiate claims directly through CBP or request DHL's customs brokerage services to file on their behalf.
Compliance systems must now track two distinct data points per entry: (1) whether the entry falls within the 80-day Phase 1 liquidation window, and (2) whether the importer of record was the shipper or the carrier. Misattributing the filing party creates duplicate claim risk or missed refund eligibility.
The phased rollout structure suggests additional eligibility windows will open for entries liquidated outside the initial 80-day period. CBP has not published the Phase 2 timeline, but compliance teams should architect their tracking systems to flag older entries that may become eligible as subsequent phases launch. HTS classification accuracy on original entries directly affects refund claim validity—any misclassification that inflated duty calculations under IEEPA rates will carry through to refund amounts.