U.S. Customs and Border Protection expects to deploy April 20 the first phase of its process for refunding IEEPA tariffs. While affected importers should utilize this process to pursue refunds, they should also continue to file timely protests and consider filing court cases to preserve their legal right to such refunds.
Despite a recent change in the underlying litigation, the Court of International Trade has directed CBP to refund IEEPA tariffs to the importers that paid them. In response, CBP has been developing within its Automated Commercial Environment new functionality for submitting and processing refund claims that will be called Consolidated Administration and Processing of Entries.
According to two recent messages (available here and here) CBP said it will launch the first phase of CAPE on April 20. According to CBP phase 1 will be limited to certain unliquidated entries and certain entries within 80 days of liquidation.
Under the CAPE process, CBP said, importers of record or their authorized customs brokers may file a CAPE declaration covering up to 9,999 entries and CBP will review the declaration and adjust the covered entries to remove IEEPA tariffs. Once this processing is complete, CBP said, unliquidated entry summaries will be set to liquidate 45 days from the declaration acceptance date, except for entries in suspended, extended, or “under review” liquidation status. Liquidated entry summaries will reliquidate the next business day.
According to CBP, individual entry summary refunds will be consolidated by IOR or designated party and liquidation date before they are dispersed in one lump sum. For unliquidated entries other than warehouse entries and entries with extended, suspended, or “under review” liquidation status, CBP said, importers and authorized brokers may anticipate that valid IEEPA tariff refunds will generally be issued within 60 to 90 days following acceptance of a declaration, unless a compliance concern requires further CBP review. This timeframe includes 45 days for CBP review plus additional time to process the refund.
While CBP’s updates provide valuable information about the anticipated CAPE process, there are still a number of factors that could impact or delay it. Importers are therefore strongly advised to not rely solely on the CAPE process in pursuing such refunds.
STR continues to recommend that importers also monitor the dates of liquidation of their affected entries and file timely protests of any such liquidations with CBP. STR continues to believe there is no immediate need for importers to file their own lawsuits at the CIT, although (1) a suit may be the only way to recover refunds for finally liquidated entries and (2) there may be other compelling considerations that support a decision to file now (click here for more details).
For more information or assistance, please contact us at messages@strtrade.com or via your usual STR contact.
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