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Updated April 12, 2026
The American customs announced that on April 20, the first online form of the CAPE system for requesting a refund of IEEPA tariffs, the so-called reciprocal tariffs, will be released. With the first form, it will be possible to submit a request for a refund for the American tariffs that have not yet been settled [unliquidated]
Updated March 24, 2026
The procedure for requesting a refund of American tariffs, referring to the IEEPA tariffs also known as reciprocal tariffs, is now clear and there is no need to file an appeal with the Court of International Trade - CIT. In practice, the refund procedure that was previously divided into two steps, namely the legal procedure with the Court of International Trade followed by the administrative appeal procedure with American customs, is now simplified and reduced to just the administrative appeal.
Following the decision on March 6, it is clear that for the refund request of tariffs only the administrative appeal and the refund request via the ACE electronic system, that is, the American customs system that manages import clearance operations in America, are sufficient. Let's remember that American customs is updating the system and, by the end of April, a dedicated environment for refund requests of IEEPA tariffs paid to import into America during the period from April 26, 2025, to February 23, 2026, will be published
During the period in question, there were 53 million imports into America subject to IEEPA tariffs. The relevant importers involved are more than 300,000. The IEEPA tariffs collected amounted to about 170 billion dollars. These are impressive figures that give an idea of the organizational effort required for the implementation of the IEEPA tariff refund procedure.
In practical terms, during the refund, the IEEPA tariffs will be reimbursed and the traditional, historical tariff, known as the MFN - Most Favored Nation tariff, will be applied.
Importation into America of Cosmetic Products
Importation into America of Industrial Machinery
Importation to the United States of Golf Shoes
Updated March 9, 2026
The Court of International Trade has ordered American customs - CBP - to refund the so-called reciprocal IEEPA tariffs paid until February 23, 2026
On March 4, 2026, Judge Richard K. Eaton of the U.S. Court of International Trade (CIT) ordered the U.S. Customs and Border Protection (CBP) to proceed with the refund of the so-called reciprocal IEEPA tariffs collected under the International Emergency Economic Powers Act, ruling that these tariffs are illegitimate in light of the recent decision by the Supreme Court of the United States.
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The American court's decision has a national scope and applies to all registered importers who paid American IEEPA tariffs. In other words, Judge Richard K. Eaton's decision is not limited exclusively to the petitioners in the procedure, and it is therefore not necessary to be a party to the procedure, nor to initially approach the Court of International Trade to be entitled to the IEEPA tariff refund request.
Although the court initially ordered American customs to immediately start the refund process, the execution of the order was temporarily suspended on March 6, 2026, after American customs reported technological and operational limitations in handling the enormous number of customs declarations involved — about 53 million import operations.
American customs is therefore preparing a dedicated telematics system for the refund of IEEPA reciprocal tariffs, which should be operational by the end of April.
Clarified the erga omnes scope of the Court of International Trade's decision, the refund process must be submitted via the American customs telematics system ACE (Automated Commercial Environment).
The ACE system represents the digital platform through which importers and their customs brokers manage customs declarations, liquidation procedures, and administrative requests with the U.S. Customs and Border Protection (CBP).
Initially, it was assumed that the refund of reciprocal tariffs was limited to import operations into the United States for which the tariffs had not yet been liquidated by American customs.
The Court of International Trade's decision clarified that American customs must also proceed with the refund of already liquidated tariffs.
In situations where liquidation has already occurred, the court's order requires American customs to reopen the liquidation procedure, recalculate the tariff excluding the IEEPA component, and thus proceed with the refund of the excess paid tariff.
Updated March 2, 2026
It is expected that the United States Supreme Court (SCOTUS) decision regarding the illegitimacy of the so-called reciprocal American IEEPA tariffs will become final within 32 days from the date of the SCOTUS judgment. Once final, the attorneys of the pilot case will begin consultations with the Government and the Court to define the next procedural steps.
First of all, it should be noted that refund requests can only be submitted by Importers of Record, as passive taxpayers who actually paid the tariffs. Secondly, it should be noted that since February 6, 2026, American customs issues refunds only via ACH to checking accounts held at banks in America. Importers will need to quantify the amount of IEEPA tariffs paid for each import operation into the United States.
Although this type of appeal can be exercised until February 2027, it is advisable to file before the SCOTUS mandate becomes final.
Formal objections to U.S. Customs and Border Protection (CBP) within 180 days from the date of customs declaration liquidation. Since the liquidation process takes about 10 months, this route is considered slower. We recommend this step only as a precautionary measure.
| Event / Action | Deadline | Notes |
|---|---|---|
| Effectiveness of SCOTUS Judgment | March 24, 2026 | 32 days after the decision. Triggers the mandate and the start of negotiations with the Government. |
| CIT Appeal Filing | Immediate | Recommended before 03/24/2026 |
| CBP Objection | Within 180 Days | From the date of liquidation (approximately 314 days after entry). Precautionary measure. |
| Statute of Limitations | Feb. 2027 | Two years after the start of the IEEPA program |
Updated February 20, 2026
The Supreme Court of the United States today issued a historic ruling definitively overturning the IEEPA tariffs, known as reciprocal tariffs, imposed based on the International Emergency Economic Powers Act.
According to the decision, the 1977 law: does not authorize the president to impose tariffs as a tool of trade policy; the power to tax and impose tariffs is an exclusive of the United States Congress, according to the interpretation of the U.S. Supreme Court
The judgment particularly concerns the IEEPA tariffs defined as “reciprocal”, introduced by the Trump administration starting April 2, culminating with the agreement with European Commission President Von der Leyen, which had set tariffs at 15% for Europe.
List of documents to submit to American customs
Procedure to activate the tariff refund practice
Updated February 8, 2026
To receive the refund of American tariffs, you must have a checking account at an American bank. From February 6, 2026, American tariff refunds will only be made electronically, and American customs will no longer send checks)
The rule also applies to foreign Importers of Record [IOR] who will need to have a checking account at an American bank. The case applies, for example, to all Italian companies exporting to America with Incoterm DDP without having their own subsidiary in America. We advise preparing in advance for a possible American Supreme Court decision that would revoke the so-called reciprocal tariffs.
Open a business checking account in America
To avoid delays or interruptions in refunds, importers must be enrolled in the ACH Refund program via the ACE portal. Importers not yet enrolled must submit an ACH Refund request via the ACE portal. The rule applies to refunds issued in favor of all the following parties:
Updated December 27, 2025
It is necessary to request from American customs, before the end of 2025, an extension of the liquidation of tariffs on imports into the United States made from mid-April 2025 to preserve the right to the IEEPA tariff refund in case a Supreme Court ruling deems them illegitimate.
The Supreme Court of the United States will review the legitimacy of American tariffs imposed under the IEEPA in November, but a final decision is expected only around mid-2026. Based on this schedule, your eligibility to request a refund could be compromised if the court declares the tariffs illegitimate.
The first imports into America subject to IEEPA tariffs were cleared in mid-April 2025. The tariffs related to many of them will thus be liquidated before the final judgment, causing the deadlines for submitting the tariff refund request to expire. To protect the potential right to a refund, it is possible to resort to one of the two available options before tariff liquidation:
Each of these options has advantages and disadvantages, but they are the only ways to ensure eligibility for potential future refunds of tariffs already paid or to be paid. In summary: the extension grants time, the appeal preserves refund rights after tariff liquidation.
It is recommended to submit appeals, as they can be filed electronically and are easier to track. In any case, it is strongly advised to carefully consider your options to not miss the opportunity to obtain a refund on tariffs already paid.
For imports made in April 2025, the corresponding time windows will begin to close between the end of 2025 and January 2026, according to the scheduled liquidation date. It is therefore crucial to know your deadlines well.
It is possible to request a refund of American tariffs paid to import goods or products into the United States if within five years the same goods or products are exported to Canada in whole or in part.
The refund request must be made to American customs and the refund amounts to 99% of the American tariffs paid at import. The customs refund practice is not particularly complex to prepare and the deadlines to obtain the refund are not excessive.
This is an American customs standard that has always been in effect and not a recent novelty. The practice must be managed by an experienced American customs operator in this type of operations, and ExportUSA can help you through the network of American customs professionals with which it collaborates.
ExportUSA handles the accounting for all types of American companies and all types of businesses. In addition to bookkeeping, we prepare and present end-of-year income statements as well as quarterly [or monthly, depending] sales tax statements.
https://www.exportusa.eu/accounting-services-exportusa.php
ExportUSA offers all logistics services for the United States. We have a warehouse in Ohio that we make available to our clients
https://www.exportusa.eu/logistics-services-exportusa.php
ExportUSA opens US incorporated companies in all of the United States. We can open both LLCs and corporations
https://www.exportusa.eu/opening-a-company-exportusa.php