Recent developments at the federal level indicate that the process for potential tariff refunds is moving forward, with important implications for ABPA members.
A newly filed declaration from U.S. Customs and Border Protection (CBP) confirms that the agency is actively developing a system to process refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). This marks a meaningful shift from ongoing legal and policy discussions to operational implementation.
System Development Underway
CBP is building a new functionality within its Automated Commercial Environment (ACE) system—referred to as CAPE—that will allow for the submission, review, and processing of refund claims. The system is expected to include a claim portal, mass processing capabilities, and mechanisms for reviewing and issuing refunds.
While the system is not yet live, CBP has indicated that development is well underway, with key components nearing completion. This signals that the refund process is approaching a stage where importers may soon be able to take action.
Phased Approach to Refunds
According to CBP, the initial phase of the refund process will focus on more recent entries, specifically those that are unliquidated or still within the 90-day window for voluntary reliquidation. These entries are expected to represent a majority of affected transactions.
CBP has also indicated that future phases of the system are expected to address more complex scenarios, including entries that have already been fully liquidated. This suggests that the potential scope of refunds may extend further than initially anticipated.
Scale and Impact
The volume of tariffs at issue is substantial, with CBP reporting that tens of thousands of importers have already taken steps to position themselves to receive electronic refunds. The total value of duties potentially subject to refund is significant, underscoring the broad impact this process may have across industries, including the automotive aftermarket.
For ABPA members, many of whom have been directly affected by tariffs on imported collision repair parts, these developments represent a potentially meaningful opportunity.
Preparing for What Comes Next
While details of the claims process are still being finalized, members should begin preparing now to ensure they are positioned to take advantage of any available refund opportunities. This includes:
- Identifying imports that may have been subject to IEEPA tariffs
- Coordinating with customs brokers or trade advisors
- Ensuring the ability to receive electronic refunds from CBP
- Maintaining accurate records of relevant entries and duty payments
Taking these steps in advance may help avoid delays once the system becomes operational.
ABPA Will Continue to Monitor
The ABPA will continue to closely monitor developments related to tariff refunds and will provide updates as additional information becomes available.
While the Association is not providing legal or customs advisory services, we remain committed to keeping our members informed and positioned to respond as this process evolves.
