IEEPA Tariff Refunds: Essential ACE Setup, ACH Enrollment, and Reporting Requirements

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    UPDATE: CBP Creates REV-613 ACH Rejected Refunds Report (March 26, 2026)

     

    CBP has launched a new ACE report to track electronic refund rejections, critical for importers preparing for IEEPA tariff refunds through the CAPE system. Here’s what importers must know:

     

    REV-613 ACH Rejected Refunds Report

    • Purpose: Identifies refunds rejected solely due to missing or incorrect banking information in ACE
    • Status Indicator: “SAP ACH Rejected”
    • Access: Requires only Trade Account ACE ID in the report prompts window

    REV-603 Trade Refund Report (Companion Report)

    • Purpose: Tracks refunds returned by banks due to incorrect account details
    • Status Indicator: “Check/ACH Returned” (Refund Secondary Status)
    • Action Required: Correct ACE banking info and request replacement refund

    Why This Matters for IEEPA Refunds

    With CBP’s mandatory ACH policy (effective February 6, 2026) and CAPE processing imminent, rejected refunds due to banking errors will delay IEEPA recoveries. Only ~21,000 of 330,566 affected importers have completed ACH setup. Monitor both reports weekly.

     

    Replacement Refund Process

    CBP guidance: Requesting Replacement Refunds

     

    CBP is expected to issue updated guidance shortly. Importers should run REV-613 immediately using your Trade Account ACE ID to identify any prior rejections blocking IEEPA refund readiness.

     

    With the CIT directing CBP to process IEEPA tariff refunds through the new CAPE system in ACE and CBP confirming all refunds will issue exclusively via ACH electronic transfer (no paper checks since February 6, 2026) importers must have active ACE Portal access and ACH enrollment using a U.S. bank account to receive payments when CAPE launches.

     

    Required ACE Actions

    Importers need to complete these three steps to confirm IEEPA refund eligibility and prepare for CAPE processing:

     

    1. ACE Portal Account

    Verify active importer account status with access to relevant entry summaries. New account registrations require internal IT/security approvals and can take several days to weeks.

     

    2. ACH Refund Enrollment

    Submit ACH Refund application through ACE Portal’s ACH Refund Authorization tab, linking a U.S. bank account (foreign IORs must designate a U.S. account for refunds). Once approved, IEEPA refunds deposit automatically.

     

    3. Generate Key Reports

    Run specific reports to quantify IEEPA exposure and track liquidation status. There are specific reports that identifies entries with Chapter 99 IEEPA HTS codes, duties paid, and show liquidation dates (critical for 180-day protests per Judge Eaton’s March 20 order).

     

    Why These Steps Matter Now

    Judge Eaton’s March 20 Atmus Filtration order requires importers to monitor IEEPA entry liquidations and file 180-day protests under 19 U.S.C. § 1514 where no CBP reliquidation agreement exists. CAPE Phase 1 excludes AD/CVD, FTZ, drawback, and certain liquidated entries, making these ACE reports essential for identifying protest-eligible entries and confirming CAPE coverage.

     

    CBP reports 330,566 importers paid IEEPA duties, but only ~21,000 entities have completed ACH setup leaving the vast majority unready for electronic refunds.

     

    Our team can assist with:

    • Verifying ACE account status and resolving access issues
    • Completing ACH enrollment applications
    • Generating and interpreting ACE reports
    • Identifying entries requiring timely 180-day protests

    To confirm your ACE readiness or request assistance with these requirements please contact [email protected]

     

    Denise Calle is a Principal at Olsson Frank Weeda Terman Matz PC specializing in U.S. international trade and customs law.

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