Certain tariff refunds may be available, but eligibility depends on how the import was structured

Manufacturers that imported goods subject to certain tariffs may now have an opportunity to review whether they are eligible for a refund.

Following the Supreme Court’s February ruling that certain tariffs were not authorized under the International Emergency Economic Powers Act (IEEPA), U.S. Customs and Border Protection developed the Consolidated Administration and Processing of Entries system, known as CAPE. The system is intended to provide a process for eligible refund claims tied to certain tariffs that were paid.

For manufacturing businesses, this is worth reviewing because tariffs can affect material costs, imported components, finished goods, inventory values and cash flow planning. The refund process will not apply to every company or every tariff charge, but manufacturers that imported directly may want to determine whether they qualify.

Who may be eligible for a tariff refund?

The first question is whether your company was the importer of record.

In general, the refund process is available to the importer of record or an authorized customs broker. If your manufacturing business directly imported goods and paid the applicable tariffs, you may be eligible to submit a refund claim through CAPE.

If tariff costs were passed along to your company by a vendor, supplier or distributor, the situation may be different.

For example, if another company imported the goods and included the tariff cost in its pricing, that company may be the importer of record. In that case, your business may not be eligible to claim the refund directly through CBP.

This distinction is important. A manufacturer may have felt the cost of tariffs in its pricing, but eligibility depends on the customs entry records and who was legally responsible for the import.

What entries are eligible during Phase 1?

The refund window opened on April 20, 2026. During Phase 1, only certain entries qualify.

According to the information currently available, Phase 1 applies to certain unliquidated entries or entries within 80 days of liquidation. This means manufacturers should review the timing and status of their entries before assuming a refund is available.

If your company works with a customs broker, this is a good time to ask for a review of potentially eligible entries. If your company manages imports internally, your team should review entry records, liquidation dates and tariff payments to determine whether any entries fall within the current eligibility window.

What Manufacturers Should Review Now

Manufacturers do not need to overhaul their processes to begin evaluating eligibility. The first step is gathering the right information. Start by confirming:

  • Whether your company was the importer of record
  • Whether the tariffs were paid directly by your company
  • Which entries may be tied to the affected tariffs
  • Whether the entries are unliquidated or within 80 days of liquidation
  • Whether your ACE Portal account is active
  • Whether your bank account information is current for ACH refunds
  • Whether your customs broker is authorized and prepared to assist

CBP requires filers to have an ACE Portal account and updated bank account information so approved refunds may be issued by ACH. The CAPE system is designed to consolidate refund application submissions, which should help companies submit eligible entries in a more organized format.

How the CAPE Submission Process Works

Filers making a declaration through CAPE will need to use a .CSV file. Each submission may include up to 9,999 entries, and multiple submissions are allowed if a filer has more entries to submit.

For manufacturers with a large number of imports, this format may make the process more efficient. However, it also makes accurate records important. Entry numbers, tariff information, liquidation status and importer details should be reviewed carefully before submission.

Approved refunds are expected to be issued within 60 to 90 days after the CAPE declaration is accepted. Manufacturers should keep in mind that this timing begins after acceptance, not necessarily after the company begins reviewing its records or preparing the submission.

What if the tariff was passed through by a supplier?

Some manufacturers may not be the importer of record but may have paid higher costs because tariffs were included in vendor pricing. In that situation, the company may not be able to file directly through CAPE.

However, it may still be useful to review supplier agreements, invoices and purchase terms. If a supplier receives a refund tied to tariffs that were passed along to customers, the agreement between the supplier and customer may determine whether any credit, adjustment or reimbursement is available.

This is especially relevant if tariffs were listed as a separate line item or surcharge. If the cost was simply included in the product price, it may be more difficult to trace.

Why this Matters for Planning

For manufacturers, tariff refunds may affect more than cash flow. Depending on the amount and how the original tariff costs were recorded, a refund could touch inventory accounting, cost of goods sold, vendor credits, customer pricing or financial reporting.

That does not mean every refund will be material. But it does mean the review should involve the right people. Owners, controllers, CFOs, purchasing teams, customs brokers and advisors may all have a role in determining eligibility and documenting the claim.

Questions?

Manufacturers should begin with a simple review: identify whether the company directly imported goods subject to the affected tariffs and whether it was listed as the importer of record.

From there, review entry status, liquidation dates, ACE Portal access and ACH refund information. If a customs broker handles your entries, ask whether they have reviewed your account for potential CAPE refund eligibility.

The refund process is still limited in Phase 1, but manufacturers with eligible entries may benefit from reviewing their records now rather than waiting until later phases or deadlines create more pressure.

Additional information and FAQs regarding the IEEPA refunds can be found at: CBP IEEPA Refunds.