For a small importer, the IEEPA refund should have been the simplest money of the year. The Supreme Court struck the tariffs down in February, and CBP has been working to return $166 billion in IEEPA tariff revenue to the companies that paid it. In practice, the owner of a small housewares or parts importer can spend evenings pulling entry summaries from three different brokers, working out which shipments carried the extra duty, and checking which entries are about to age out of eligibility. Every week the list sits unfinished is another week the business goes without working capital it already paid out.
A refund system that runs on entry numbers
CBP built a new tool inside its Automated Commercial Environment, called CAPE, to handle the refunds. On paper it is lean. CBP's refund guidance says a declaration is a CSV file of up to 9,999 entry numbers, and no other data fields are required. Refunds generally arrive 60 to 90 days after a declaration is accepted.
The difficulty sits in the rules around that file. Only the importer of record, or the licensed broker who filed the entries, can submit a declaration, and both need an ACE portal account. A broker can only claim entries filed under its own filer code. Entries liquidated more than 80 days earlier are rejected, as are entries already claimed on an earlier declaration. Once accepted, a declaration cannot be amended. Refunds go to the importer of record or its designated notify party, by direct deposit, so the bank details on file in ACE have to be right as well.
Large importers have trade compliance teams who already reconcile entries to invoices as a matter of routine. A small importer usually does not. Its entries are scattered across the ocean forwarder who handled container freight, the courier whose brokerage arm cleared air samples, and perhaps a second forwarder the business tried for a few months. Each of those parties holds a piece of the record, and none of them sees the whole picture.
Where the filings break down
CBP's own numbers show how often the paperwork goes wrong. In a sworn declaration to the Court of International Trade in July, a CBP trade official reported that 229,609 declarations had been submitted since April, of which 161,792 passed the initial file checks. The main reasons for failure were mismatches between the importer of record and the filer, entry numbers that were the wrong length or did not exist, and CSV files that did not match CBP's template. These are clerical errors, not legal ones, and they are exactly the errors a part-time bookkeeper makes when copying entry numbers out of PDF statements.
Declarations that clear the file check still face entry-by-entry validation. Millions of entries were rejected at that stage because they were past CBP's reliquidation window, carried no IEEPA tariff line, or had already been claimed.
Source: U.S. Customs and Border Protection, CIT declaration
View data
| Entries | |
|---|---|
| Accepted for refund | 24.4M |
| Already reliquidated | 16.7M |
| Rejected at entry check | 4.8M |
The same filing noted 9,837 refunds that had been approved but not sent to the Treasury because the importer had never supplied bank account details. That is money already won and left waiting for a form. Some owners cannot get as far as filing at all. CBS News reported in May on the co-founder of a Minnesota baby products company, owed roughly $50,000, who was locked out because ACE said her tax ID was already linked to another account. The same report found that about 15% of early claims had been rejected.
Why brokers, spreadsheets and recovery firms only go part of the way
The obvious answer is to hand the job to the customs broker, and for importers with a single broker and clean records that often works. The limits appear as soon as the history is messy. A broker can only file what it filed, so an importer with three brokers needs three separate efforts and has to make sure nothing falls into the gaps between them. Brokers are also handling the same refund work for every client at once, alongside a tariff schedule that keeps changing, and a small account with a few hundred entries is rarely first in the queue.
Spreadsheets are the default fallback. An owner or controller exports entry summaries, filters for the IEEPA lines, and checks liquidation dates by hand. This works until the details multiply: entries flagged for reconciliation, entries that liquidated last week and now sit inside the 80-day window, entries already claimed by a broker without telling anyone. Because accepted declarations cannot be edited, a mistake is fixed only by filing again, and a duplicate gets rejected outright.
Trade attorneys and refund recovery firms fill a real need, especially for entries that have finally liquidated. Supply Chain Dive reported that roughly $11.4 billion, or 6.9% of IEEPA tariffs, sits in finally liquidated entries that CAPE could not yet process, with a Justice Department appeal complicating the path. For those claims, legal help may be the only option. For the larger share of a small importer's entries, the problem is less legal than administrative: getting a complete, correct list into the right portal before deadlines pass. Professional fees can take a meaningful bite out of a modest refund.
What has become easier
The refund process is now better defined than it was in the spring. CAPE runs in phases, and in late June CBP added support for entries flagged for reconciliation. Supply Chain Dive reported 2.2 million submissions of that kind within weeks of launch, and that CBP had paid out $100 billion by the end of July. The rules on eligibility, filer codes and rejection codes are published and stable enough to build around.
The underlying data has also become easier to reach. CBP points importers to an ACE report that can be filtered with an IEEPA tariff indicator to list every entry line with those duties assessed, and to a second report that links accepted declarations and refund numbers back to individual entries. Together with broker statements, commercial invoices and bank deposit records, an importer has what it needs to work out which entries are owed, which have already been claimed and by whom, and which refunds have actually arrived. The answers are spread across systems, but they are no longer guesswork.
That combination of a fixed set of rules and a scattered but accessible paper trail suits custom software. An automation built for one importer can collect entry data from each broker and from ACE reports, check every entry against CBP's published eligibility and rejection rules before anything is filed, prepare separate files for each filer code, and follow each refund until it shows up in the bank account. It will not settle the litigation over finally liquidated entries. It can make sure the larger share of a small importer's refund is not lost to a formatting error, a duplicate or a missed window.