Refunds of IEEPA tariffs are starting to be processed and the first repayments could be issued as soon as May 11. However, timely protests against liquidation of affected entries should still be considered and filed as necessary.
U.S. Customs and Border Protection deployed April 20 the first phase of its Consolidated Administration and Processing of Entries system for submitting and processing IEEPA tariff refund claims. Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation, and CBP has not specified when additional phases may be deployed or which additional entries they may cover.
In an April 28 update to the Court of International Trade, CBP said CAPE was working successfully, even though importers have raised some concerns. During its first week a total of 75,306 refund declarations were submitted, with 47,315 passing file-level validations. About 11.2 million entries covered by these declarations passed the entry-specific validations and were accepted for the removal of IEEPA tariffs, which the CIT said represents about 21 percent of all entries subject to IEEPA tariffs. Another 2.1 million entries were rejected for failing those validations.
Of the 11.2 million entries that passed, 1.7 million (about three percent of all entries subject to IEEPA tariffs) had been liquidated and were in the refund process. CBP, which has said that refunds will generally be issued within 60 to 90 days following declaration acceptance, advised that the first refunds could be deposited into designated bank accounts on or about May 11. The CIT has directed CBP to provide another update on May 12.
Importers can run a new ES-022 report in the Automated Commercial Environment to see their CAPE claim status, and the ES-701 courtesy notice of liquidation report may begin showing entries reliquidating with refunds and interest calculations, though actual refunds may not be provided immediately.
In the meantime, there are still a number of factors that could impact or delay the refund process. For example, the Department of Justice still has until June 6 to file an appeal of the CIT order directing CBP to refund all IEEPA tariffs. Importers should therefore not rely solely on CAPE in pursuing refunds.
In particular, STR continues to recommend that importers monitor the dates of liquidation of their affected entries, including those that have been accepted into CAPE, and file timely protests of any such liquidations with CBP. Importers should also timely file protests on entries that have not been filed into CAPE or are not currently eligible for that process.
STR continues to believe there is no immediate need for importers to file their own lawsuits at the CIT to preserve their rights to IEEPA tariff refunds, 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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