IEEPA Tariff Refunds: Recover Overpaid Duties and Maximize Cross-Border Savings

Understanding IEEPA tariff refunds can be complex — especially with recent regulatory changes and new filing mechanisms.

In this webinar, Jean-Daniel Vermette, alongside experts from Descartes, breaks down how importers can recover duties paid under IEEPA and navigate the refund process efficiently.

From the Supreme Court ruling to the rollout of the CAPE system and ACE portal requirements, this session provides practical, actionable insights to help you secure your refunds and optimize your customs strategy.

Whether you’re a finance leader, importer, or supply chain professional, this webinar will help you identify opportunities and avoid costly mistakes.

What you will learn: 

Who is this webinar for?

✔ Finance Leaders
CFOs, Finance Directors, Controllers

✔ Supply Chain & Operations Leaders
Head of Supply Chain, Logistics Managers, Operations Directors

✔ Import/Export & Trade Compliance Professionals
Customs Managers, Trade Compliance Specialists

✔ Business Owners & Executives
Companies importing into the U.S. looking to reduce costs and recover cash

Webinar agenda:

• • Overview of IEEPA tariffs and recent legal developments
• • Introduction to the CAPE refund mechanism
• • ACE portal: setup, access, and reporting
• • Eligibility and refund process explained
• • How to maximize your refund and ensure compliance
• • Additional duty recovery opportunities (drawback, classification, etc.)
• • Live Q&A session

Questions and Answers

Below you will find the answers to the questions raised during the webinar, prepared by our expert Jean-Daniel VERMETTE.

Please note that these answers are provided for general information purposes only and do not constitute legal, tax, or financial advice.

If you have questions related to your specific situation or that of your organization, we encourage you to contact us directly.

Does the bank account need to be in the U.S., or can it be a Canadian USD account?

The refund must be issued to a U.S. bank account via ACH, and it must be in USD. Non-U.S. accounts are not accepted.

What if I’m not set up on the ACE portal? Can you do it for us?

You (the importer) must create the ACE account yourself. However, support teams can guide you through the setup process, which has been simplified recently.

Are couriers like UPS or DHL requesting refunds on behalf of companies?

Only the importer of record can request the refund.
If a courier or broker acted as the importer of record, they must initiate the refund, and you would need to arrange reimbursement with them separately.

If duties were passed along the supply chain, who gets the refund?

The refund always goes to the importer of record, even if the cost was passed to distributors or customers.
Any redistribution must be handled privately between parties.

What about imports outside the 180-day window?

Phase 1: Covers unliquidated entries and some recently liquidated ones (within ~80 days).

Other entries will be handled in future phases, with guidance still pending.

Are refunds dependent on liquidation status?

Refunds are not tied to liquidation timing but rather to the filing of the CAPE declaration, typically processed within ~90 days of submission. 

Will brokers automatically file refunds?

No. Refunds are not automatic.
The importer of record must initiate the process, even if a broker handled the shipment.

What if I can’t access my ACE account?

This may be due to high demand or system issues.
You should contact the ACE help desk, which typically resolves issues within about a week.

Do you charge upfront fees?

No upfront cost.
Fees are contingent on success — you only pay if a refund is recovered.

Are aluminum and steel tariffs (Section 232) included?

No. Section 232 tariffs are not part of the IEEPA refund program.

If we export to the U.S. but our U.S. customer pays the duties, can we claim the refund?

No. Only the U.S. importer of record can claim the refund, even if another party covered the cost.

What if I don’t know the contact listed on the original 5106 form for ACE?

You’ll need to work with CBP (Customs and Border Protection) to verify and recover the account details.
This may require additional documentation.

How can I see how much I paid in IEEPA tariffs?

You can generate reports directly in the ACE portal to view all tariff-related data and identify eligible amounts.

Will the importer of record always be the customs broker?

No. In most cases, the importer of record is the company purchasing and importing the goods, not the broker.
However, in some cases (e.g., small shipments), a broker or courier may act as the importer of record.

Who needs to initiate the refund process?

Always the importer of record.
Brokers or carriers will not initiate refunds automatically.