US tariff refund process begins: What importers and DDP exporters should prepare for
The United States is preparing to launch one of the largest customs duty refund programmes ever undertaken, following the Supreme Court ruling that invalidated tariffs imposed under emergency powers.
The judgment overturned duties introduced under the International Emergency Economic Powers Act (IEEPA), which had applied across multiple trading relationships including imports from China, Canada and Mexico. As a result, the US government now faces the task of returning tens of billions of dollars in duties collected during the period the tariffs were in force.
Industry estimates suggest that between $166 billion and $180 billion in tariffs were paid by importers, creating a complex administrative challenge for US Customs and Border Protection (CBP).
CBP building automated refund system
To manage the scale of the process, CBP is developing a new digital system within its Automated Commercial Environment (ACE) platform to process refund claims.
The new functionality — known as Consolidated Administration and Processing of Entries (CAPE) — will allow importers and customs brokers to upload lists of affected entry summaries through the ACE portal. The platform will then validate the entries, remove the relevant tariff codes and automatically recalculate duties before refunds are issued electronically.
Development of the system is progressing rapidly. CBP reports that the claim submission portal is around 70% complete, the review and liquidation module approximately 80%, while the refund-processing component and the mass-processing engine are still being finalised.
Once operational, the system is expected to significantly reduce the administrative burden that would otherwise be created by processing millions of individual refund claims.
A large-scale administrative exercise
The scale of the refund process is unprecedented.
More than 330,000 importers may be eligible to recover duties covering over 50 million customs entries submitted during the tariff period. CBP has indicated that manually reviewing each claim would require millions of labour hours, making automated processing essential.
Under the proposed approach:
• Refunds may be issued as consolidated payments covering multiple entries
• Statutory interest will be added to eligible refunds
• CBP will verify entries to confirm compliance status and outstanding obligations
The objective is to ensure companies can recover duties without being forced into lengthy legal action.
Why exporters selling DDP should pay attention
The implications extend beyond US-based importers.
Many international exporters selling goods to US customers under Delivered Duty Paid (DDP) terms effectively act as the importer of record. In these cases, the exporter may have been responsible for declaring goods to US customs and paying the duties directly.
As a result, exporters that shipped goods under DDP arrangements may also be eligible to recover duties paid during the tariff period.
However, confirming eligibility may require detailed review of customs data, including:
• importer of record declarations
• entry summaries and tariff classifications
• liquidation status of entries
• documentation confirming duty payments
For companies that traded heavily with the US during this period, identifying recoverable duties may require a structured review of historical shipments.
Turning regulatory change into opportunity
Major policy shifts in international trade often create both operational risk and financial opportunity. The tariff refund process now underway highlights the importance of accurate customs data, strong compliance processes and experienced brokerage support.
Logicall’s global customs specialists work with importers and exporters to analyse historical entries, validate tariff classifications and support refund claims through US customs systems.
Through its integrated logistics network and customs brokerage capability, Logicall helps businesses navigate changing regulatory environments while keeping international supply chains moving.
If your company imports into the United States or sells goods DDP to US customers, Logicall’s customs experts can help you review historical shipments, assess potential refund eligibility and ensure claims are submitted efficiently and compliantly.