What if your company has already paid tariffs it may now be able to recover?
For many U.S. businesses importing products from China and across Asia, that’s no longer a hypothetical question.
On July 23, U.S. Customs and Border Protection (CBP) expanded its claims process, allowing eligible importers and authorized customs brokers to electronically submit certain refund requests for duties collected under the International Emergency Economic Powers Act (IEEPA) through the ACE Portal using its Consolidated Administration and Processing of Entries (CAPE) system.
According to CBP, accepted and valid requests are generally expected to be processed within 60 to 90 days.
At first glance, the announcement may sound like another procedural customs update.
Its business implications are much broader.
For companies that qualify, recovering previously paid duties could strengthen working capital, improve cash flow, increase purchasing power, and create additional flexibility for inventory, operations, or future growth.
In today’s uncertain trade environment, that’s an opportunity worth understanding.
At a Glance: What Changed?
- CBP expanded electronic submission of certain eligible IEEPA-duty refund requests through its CAPE system.
- Eligible importers and authorized customs brokers may submit claims through the ACE Portal.
- Accepted and valid requests are generally expected to be processed within 60–90 days.
- The process applies only to eligible IEEPA-duty refund requests—not every tariff.
- Eligibility depends on factors such as entry timing, liquidation status, importer-of-record information, and supporting documentation.
More Than a Customs Story
It’s easy to view this announcement as a technical customs update.
That would be a mistake.
For many businesses, tariff refunds are ultimately about capital—not compliance.
Recovering eligible duties may improve liquidity, increase inventory purchasing power, strengthen gross margins, offset freight expenses, and improve cash-flow forecasting.
For manufacturers, wholesalers, retailers, and consumer brands importing from Asia, access to additional working capital can create meaningful operational flexibility.
The opportunity isn’t simply about recovering money that was previously paid.
It’s about putting that capital back to work.
Who Should Pay Attention?
The expanded claims process may be particularly relevant for businesses that imported products subject to qualifying IEEPA duties, including many companies sourcing:
- Consumer products
- Furniture
- Apparel and footwear
- Electronics
- Automotive products
- Industrial equipment
- Home goods
Not every importer will qualify.
The expanded electronic process applies only to certain eligible IEEPA-duty refund requests, and eligibility depends on each company’s specific circumstances, including entry timing, liquidation status, importer-of-record information, and the accuracy of customs entry data.
Determining eligibility should always be done in consultation with a customs broker or legal advisor.
The Real Challenge Isn’t Filing the Claim
Many executives assume the most difficult part of recovering duties is submitting the request.
In reality, the greater challenge often begins long before that.
Supporting documentation is frequently spread across commercial invoices, purchase orders, customs entry summaries, freight records, ERP systems, warehouse files, freight forwarders, and customs brokers.
Reconciling months—or even years—of shipment history can quickly become a significant undertaking.
According to Anton Tombu, Business Development Director at XCT Logistics, businesses often discover that the biggest obstacle isn’t filing a refund request—it’s locating and organizing the information needed to support one.
“Good decisions begin with good information,” Anton says. “Whether you’re evaluating tariff exposure, responding to a customs inquiry, or reviewing potential refund opportunities, accurate shipment records give your team confidence to act.”
The companies that respond most effectively to opportunities like this are rarely the ones with the largest logistics departments.
They’re the ones with the best information.
Organizations that maintain accurate shipment histories, commercial documentation, freight records, and customs data are often better positioned to respond not only to refund opportunities but also to audits, regulatory changes, and future supply chain disruptions.
Strong documentation is no longer just an operational best practice.
It’s a business asset.
A Practical Example
Imagine a U.S. furniture importer that sourced dozens of container loads from China over the past year.
Following CBP’s announcement, the company works with its customs broker to review historical entries and determine whether any previously paid duties qualify under the expanded claims process.
Even if only a portion of those duties is ultimately recoverable, the financial impact could be significant.
Recovered funds might help finance seasonal inventory purchases, offset transportation costs, or improve cash reserves without requiring additional borrowing.
Every company’s circumstances are different, but the example illustrates why many businesses are taking a fresh look at historical entries rather than focusing only on future imports.
Questions Every Importer Should Answer Before Pursuing a Tariff Refund
Before assuming your business has nothing to recover, consider these questions:
- Have we identified entries that may include qualifying IEEPA duties?
- Is our shipment and customs documentation complete and accessible?
- Can our customs broker quickly reconcile our entry data?
- Have we estimated the potential financial impact if duties are recoverable?
- Are our documentation processes prepared if similar opportunities arise in the future?
Even if a refund is ultimately unavailable, answering these questions can strengthen supply chain visibility and improve operational readiness.
Final Thoughts
Trade policy often creates winners and losers.
Occasionally, it also creates second chances.
For businesses that may have paid qualifying IEEPA duties, CBP’s expanded claims process presents an opportunity to revisit historical entries with fresh eyes and determine whether capital once considered a sunk cost may now be recoverable.
Whether a refund is ultimately available depends on each company’s unique circumstances and should be evaluated with a customs broker or legal advisor.
What every importer can do today, however, is understand their historical entries, strengthen the quality of their records, and ask one important question:
Have we quantified what our business may be eligible to recover?
Sometimes the smartest supply chain decisions aren’t about the next shipment.
They’re about making the most of the ones that have already arrived.
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