The long-anticipated process to recover US tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has now begun, with U.S. Customs and Border Protection (CBP) launching its new refund system.
The introduction of the Consolidated Administration and Processing of Entries (CAPE) platform on 20 April 2026 marks a critical milestone. Businesses can now begin submitting claims for duties paid during the affected period, with the first submission deadlines from 4 May 2026.
However, while access to refunds is now available, the window to act is narrow and the process itself is far from straightforward.
For UK businesses trading with the United States, and particularly those operating under Delivered Duty Paid (DDP) terms, this represents a significant financial opportunity and a complex compliance exercise.
CAPE system introduces structured but time-sensitive process
The CAPE system, accessed via the ACE portal, is the exclusive route for submitting refund claims. Only the Importer of Record or an authorised customs broker can file, using a structured declaration format that requires detailed historical entry data.
Phase 1 of the programme is now active, covering unliquidated entries and those recently finalised. This initial phase is expected to account for a significant proportion of eligible claims, but strict timelines mean businesses must act quickly to avoid missing eligibility windows.
Once claims are accepted, refunds including interest are expected within 60 to 90 days, although actual timelines will depend on the quality and completeness of submissions.
A large-scale reconciliation exercise, not a simple refund
Despite the introduction of automated systems, the process is best understood as a full customs reconciliation programme rather than a standard reimbursement.
Each claim must be validated against historical entry data, including confirmation of importer-of-record status, tariff classifications, and whether entries have been liquidated, adjusted or previously disputed.
Given the scale, with tens of millions of entries under review, submission, validation and payment will take place in phases, and delays are likely where data is incomplete or inconsistent.
For entries outside the initial phase, businesses may need to pursue alternative routes such as formal protests, typically within 180 days of liquidation, adding further complexity.
The opportunity to recover duties is not limited to US-based importers. Many UK and international exporters may also be eligible where they acted as importer of record under DDP terms.
In these cases, businesses must demonstrate full control and responsibility for the original customs entries, making data accuracy and documentation critical to a successful claim.
Early action will determine success
With submission windows already open and deadlines in force, the focus now shifts to preparation.
Businesses should prioritise identifying affected shipments, confirming importer-of-record status, verifying tariff classifications, checking liquidation timelines and consolidating supporting documentation.
Those that act early and submit accurate, well-prepared claims will be best placed to move through the process efficiently and secure full recovery.
Metro supports importers and exporters in identifying eligible entries, preparing compliant submissions and managing claims through to reimbursement. If your business has exposure to US tariffs, EMAIL our Head of Customs & Compliance, Andy Fitchett, today to assess your position and secure the recovery you are entitled to.
