Tariff Refunds Starting To Roll Out

The refund process of eligible IEEPA tariff refund claims is under way, and importers should be actively checking the status of eligible tariff refund claims.

Limited refunds began with Phase 1 through CAPE (Consolidated Administration and Processing of Entries) system operated by the U.S. Customs and Border Protection agency. CAPE will consolidate refunds of multiple IEEPA duties, including interest, rather than processing refunds on an entry-by-entry basis. 
While refunds are a real thing, the process may make it difficult for small importers to make claims, according to the Hobby Industry Coalition.

“For many small and mid-sized importers, this creates a practical burden: the process is real, but tracking remains the responsibility of the importer and its broker,” HIC said in an email to its members.
Members should avoid treating expected refunds as received cash until funds are actually paid, the HIC said.
Even where entries appear eligible, timing can vary. Certain entries, including extended, suspended, under-review, or warehouse entries, may require different timing or additional review before refunds are issued.
Companies should also be cautious about relying on third-party claims, online tools, or unofficial estimates without confirming results through their broker, ACE/CAPE records, or professional advisors.
The legal refund generally flows to the Importer of Record. How 
the importer handles the refunds is a separate accounting, tax, and customer relations question.

Companies may be in different situations: Some importers absorbed tariff costs directly and may need refunds to repair balance sheets, restore working capital, reduce debt, or rebuild inventory.
Some importers applied specific tariff surcharges to dealers, 
distributors, or customers, which may create different expectations. Some importers raised prices generally, without a separate tariff line item, making the relationship between the original tariff cost and later refund less direct.
HIC is not recommending a single approach. Each company should review its own facts with its broker, accountant, legal counsel, and management team before making commitments.