Refunds of IEEPA tariffs continue to be processed and the first repayments are now being issued. 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 a May 12 update to the Court of International Trade, CBP said that 126,237 CAPE declarations had been submitted as of 7 a.m. EST on May 11, of which 86,874 had passed the file validations. The declarations that had passed the file validations as of that date and time cover 15,123,221 entries with IEEPA duties that passed the entry-specific validations and were accepted for the removal of IEEPA duties through CAPE. As of the same date and time, 8,338,081 of the accepted entries had subsequently been liquidated and/or reliquidated without IEEPA duties.
The anticipated duty refund and interest amount as of 7 a.m. EST on May 11 for the 8,338,081 liquidated and/or reliquidated entries is approximately $35.46 billion. CBP states that this amount reflects the sum of the anticipated principal to be refunded and the associated interest due, after removal of the IEEPA duties and the liquidation and/or reliquidation of the entries in accordance with all applicable laws and regulations. Only a portion of these entries and their associated refunds had been consolidated by the CAPE Refund component and sent to the Treasury Department.
CBP adds that, as of 7 a.m. EST on May 11, 1,880 consolidated refunds had not been transmitted to Treasury because ACH account information had not been provided by the importer of record or its authorized CBP Form 4811 designee.
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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