CBP's ACE-Based IEEPA Duty Recovery Process

On March 6, 2026, CBP official Brandon Lord filed a declaration revealing the scale and mechanics of the IEEPA tariff refund process. The numbers are staggering: $166 billion in potentially refundable duties across 53 million entry summaries filed by approximately 330,000 importers. CBP has proposed a 7-step ACE-based recovery process that will require importers to actively participate in their own refund. The proposed process begins with the filer — the importer directly, TariffClaim, or their broker — identifying all affected entries and compiling the required data.

CBP will then create a new declaration type within the ACE portal where importers must submit structured data identifying each IEEPA-affected entry line, the original duty amount, and the Chapter 99 HTS heading that triggered the additional duty. The declaration must be filed electronically through ACE — there will be no paper-based option. CBP has estimated a 45-day timeline from system launch to begin processing the first wave of refunds. However, the system is not yet live, and importers face a critical preparation window.

Entries approaching their 180-day protest deadline cannot wait for the new system. Importers with entries near liquidation must file protective protests now to preserve their refund rights. TariffClaim helps importers prepare for this process by auto-syncing ACE data, identifying every IEEPA-affected entry, calculating duty exposure by program and country, and assembling the structured data CBP's new declaration system will require. Whether submitting your declaration directly, having TariffClaim help you file, working through a broker, pursuing CIT litigation, or preparing for the ACE declaration process, the first step is understanding your complete IEEPA exposure.