2026 IEEPA Duty Tariff Refund Program

The Supreme Court ruled in February against the President’s use of the IEEPA statute to impose duty tariffs in response to the opioid threat and reciprocal duty tariffs. In response, the President invoked the established statute in Section 122 to impose a duty tariff that replaces those previously imposed under IEEPA to maintain these tariffs. Additionally, the established statutes of Section 301 and Section 292 were invoked.

IEEPA Duty Tariffs Refund Program

Customs and Border Patrol (CBP) indicated there will be at least two phases of the IEEPA duty refund process, starting with Phase 1, which began on April 20th.

Phase 1

What is included in Phase 1?

• Formal entries cleared (valued above $2500 or requiring other government agencies) from March 22, 2025, through February 24, 2026.
• Informal entries cleared (valued below $2,500) from January 30, 2026, through February 24, 2026.
  • The scope for low-value shipments (informal entries) is expected to be small in Phase 1.

What is NOT included in Phase 1?

IEEPA refund claims cannot currently be filed for the following entries, and customers are advised to wait for additional instructions from CBP.

• Non-electronically filed entries
• Entries outside of the above dates
• Entries subject to special circumstances found here:
  • International Emergency Economic Powers Act (IEEPA) Duty Refunds | CBP

Refund Process For Phase 1

Formal Entry (Value above $2,500)

• • DHL Express is listed as the Importer of Record:
    • As the customer’s broker and Importer of Record for these customs entries, DHL Express will automatically submit eligible imports to customs for a refund on behalf of the customer begining April 20th.
      • CBP will take 60-90 days to process refunds back to DHL Express. Customers will then be credited after an additional 2 weeks.
  • Importer (You) is listed as the Importer of Record:
    • In this scenario, the customer must use the CBP-ACE system and the Consolidated Administration and Processing of Entries (CAPE) process. Even when DHL Express was the customs broker for the import, if you were the Importer of Record for the entry, you must follow the CAPE process in the ACE system.
      • CBP will take around 60-90 days for refunds to be processed back to the customer.

Informal Entry (Value below $2,500)

• • DHL Express is listed as the Importer of Record:
    • As the customer’s broker and Importer of Record for these customs entries, DHL Express will automatically submit eligible imports to customs for a refund on behalf of the customer begining April 20th.
      • CBP will take 60-90 days to process refunds back to DHL Express. Customers will then be credited after an additional 2 weeks.
  • Importer (You) is listed as the Importer of Record:
    • In this scenario, the customer must use the CBP-ACE system and the Consolidated Administration and Processing of Entries (CAPE) process. Even when DHL Express was the customs broker for the import, if you were the Importer of Record for the entry, you must follow the CAPE process in the ACE system.
      • CBP will take around 60-90 days for refunds to be processed back to the customer.

If you had an outside customs broker for the shipment instead of DHL, please consult your customs broker regarding the IEEPA refund.

How to determine who is the Importer of Record?

Customers can use DHL MyBill to determine this.

1. Go to the Archive Dashboard
2. Download your Customs Duty Invoice
   • 
3. Look at the Entry Type
   1. If it is Entry Type 01, the customer is the Importer of Record

ACE System

Customers who were the Importer of Record must submit their refund request in the CBP ACE system, and must be registered for an ACE ACH refund account to receive their refunds. CBP will NOT be issuing checks.

• Here are the instructions:
  • ACE Portal and ACH Refunds FAQs | CBP
  • Electronic Refund Enrollment in CBP’s ACE Portal

Checklist for when you are the Importer of Record and must file in the ACE CAPE process:

• Confirm who is Importer of Record (IOR) for each entry (via CBP Form 7501).
  • Note your IR number (Importer ID) — typically your EIN/Tax ID.
    • Set up (or confirm) your ACE Secure Data Portal (ACE Portal) Importer Account.
      • Enroll for ACH refunds in ACE (bank account info) so CBP can pay refunds electronically.
        • Compile your list of eligible entries (Phase 1: unliquidated and certain entries within 80 days of liquidation) You will need the entry number.
          • Prepare and upload the CAPE Declaration .CSV using the ACE CAPE template (max 9,999 entries per upload).

Additional Resources:

CBP Webpage on IEEPA Refund

• International Emergency Economic Powers Act (IEEPA) Duty Refunds

CBP EEPA Refund Guidance Bulletin

• • Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026 Deployment

ACE Support

• ACE Portal and ACH Refunds FAQs | CBP
• Electronic Refund Enrollment in CBP’s ACE Portal 
• ACE Portal Application for Importers Resource | CBP

Frequently Asked Questions (FAQs)

What is the 2026 IEEPA duty refund program?

• CBP is making a refund mechanism available for certain duties that were imposed under the International Emergency Economic Powers Act (IEEPA). Beginning April 20, 2026, refunds are requested through one of two paths depending on who is listed as Importer of Record (IOR): (a) DHL Express as IOR (DHL must file), or (b) you/your company as IOR (your files in ACE using the CAPE process).

How do I know whether DHL Express or my company is the Importer of Record (IOR)?

• In DHL MyBill, locate the shipment duty invoice in history/Archive and view the duty invoice. Look at the “Entry Type” invoice column and if it says “Type 01” then you were the Importer of Record for the entry. Next in DHL MyBill on the invoice line click on the invoice number and on the invoice line item click on the “Image” button and open the customs documents.  Look for the CBP Form 7501 (Entry Summary) which shows your company as the Importer of Record. You will need the entry number from this document. If you are the Importer of Record, you must submit the refund request through ACE using the CAPE process. When DHL Express is the Importer of Record, DHL must submit the refund request for that entry.

What is the “IR number” asked for in the ACE account application and what should I use for it?

• The IR number is your Importer ID number. For most businesses, this is the same as your Tax ID / EIN. (Individuals may use their SSN when acting as importer, but most commercial shipments use an EIN.)

Do I need an ACE account to request refunds (if I’m the IOR)?

• Yes. Phase 1 refund requests are submitted through CBP’s web-based ACE Secure Data Portal (ACE Portal) as a CAPE Declaration upload. Importers of Record (and/or authorized customs brokers) need an established ACE Portal account, and the filer must be the IOR for the listed entries (or the broker that filed those entries on the IOR’s behalf).

What is the ACE application for importer process?

• Importers who are the Importer of Record need to (1) apply for an ACE Portal Importer Account, and (2) enroll for electronic refunds by providing bank account information to CBP through the ACE Portal (ACH refunds). This enables CBP to issue approved refunds electronically. ACE Portal Application for Importers Resource | CBP

How do I compile my list of shipment entries using DHL MyBill?

• In DHL MyBill, pull each import shipment from your duty invoice history (often found under Archive), then open the shipment’s customs documents. Use the CBP Form 7501 (Entry Summary) to capture the entry number identifier(s) you’ll need for CAPE. Build a running list as you review shipments and keep a copy of the 7501s for your records.

What is the time frame for Phase 1 of the refund process?

• CBP launched Phase 1 of CAPE on April 20, 2026. Phase 1 is limited to certain unliquidated entries and certain entries that are within 80 days of liquidation at the time the refund request is submitted. If your entries fall outside Phase 1, they may be handled in a later CAPE phase or require a different administrative path.

What is the ACE CAPE process?

• CAPE (Consolidated Administration and Processing of Entries) is CBP’s mechanism in ACE for filing IEEPA duty refund requests in bulk instead of filing entry-by-entry. You submit a “CAPE Declaration” that is essentially a list of entries numbers for which you are requesting IEEPA duty refunds. CAPE Declarations are uploaded through the ACE Portal (not through ABI).

What is the CAPE spreadsheet format and what information is required?

• CBP requires the CAPE Declaration to be uploaded as a Comma-Separated Values (.CSV) file using the CAPE template available in the CAPE tab of the ACE Portal. Phase 1 is designed so that the upload contains only the entry number list required by CBP’s template (CBP indicates no additional data fields are required beyond what the template specifies). Each individual CAPE Declaration upload is limited to 9,999 entries; you can submit multiple CAPE Declarations if needed.

Who can submit a CAPE Declaration—me or my broker?

• Only the Importer of Record for the listed entries, or the authorized customs broker that filed those entries on the IOR’s behalf, may file the CAPE Declaration in ACE.

If you have additional questions, you can contact our Customer Service Team at customerservice@preferredship.com or 1-800-827-7987.