A Complete Guide to IEEPA Trump Tariff Refunds

CBP has begun a phased process on IEEPA tariffs that may allow refunds or adjustments on certain eligible entries. Phase 1 includes the following scope of entries:

• Formal entries (valued above $2500 or requiring other government agencies) with entry summary date (this is the day duties were paid to CBP) less than 394 days ago.
  • For example, using April 20, 2026 as start date for CAPE this means entries from March 22, 2025 through February 24, 2026 would be eligible absent any other exclusions.
• Informal entries filed electronically (via ACE) with entry summary date less than 80 days ago.
  • For example, starting with submissions on April 20, 2026 this would mean entries from January 30, 2026 through February 24, 2026 would be eligible absent any other exclusions.

Certain entries are excluded from Phase 1 even if they fall within the timeframes noted above.  

Importers of record (IOR) or the Customs Broker that filed the original entry on the IOR’s behalf are eligible to file for refunds via CAPE.

Yes, for shipments where the customer was the Importer of Record and DHL Express provided customs brokerage services only, any decision to apply for the refund directly or hire DHL to file the refund on their behalf must be made directly by the customer.  If the customer chooses to hire DHL, yes, DHL can file on the customer’s behalf.  In order to file, DHL will need either the list of eligible AWBs or their associated entry numbers.  Customers should visit this link to formally request for DHL Express to file eligible IEEPA refund claims on their behalf.

If we do not receive the direct authorization from a customer who acted as IOR to file on their behalf, we will NOT submit any such claims to CAPE.  However, should the customer wish to formally advise us not to file on their behalf, they can submit that request here: DHL Not to File Authorization Form

If the customer was the IOR regardless of who files for the refund (i.e. – if DHL files), the funds will be deposited via CBP into the IOR’s ACE ACH Refund account regardless of who files for the refund in CAPE (i.e. if DHL files or if the customer files directly).  CBP will not be issuing any checks for refunds.

For information on how to set-up an ACE ACH Refund account or to verify that the account is already set-up, please visit the following CBP site:  Electronic Refund Enrollment in CBP's ACE Portal

Where DHL was the IOR, checks will be issued to the party who originally paid the duty for US based customers.  For shipments that had duty and tax billed back to the shipper or a 3rd party, DHL US will be crediting those funds to the applicable country to then distribute to the appropriate account holders.

For Phase 1 entries, CBP has advised that they expect the full CAPE refund process to take 60-90 days from when a claim is accepted into the system. This means for customers who acted as IOR, they should expect to receive their refund into their ACE ACH account within 60-90 days from when their CAPE claim was accepted by CBP. If DHL was the IOR, it is estimated that it will take another 30-90 days from DHL’s receipt of the refund to be able to reconcile and process payments to the customers who originally paid us for the duty at time of import.

If you’re unsure if you acted as the IOR, the best ways to check are the following: Review your entry documents to see if on the Entry Summary form (Customs Form 7501) you are listed on box 30 (Importer of Record field). If yes, you were the IOR. Ask your DHL representative to email our American Brokerage Services team with your IRS# and ask for confirmation as to whether or not you have a POA on file with us.

Yes, it is recommended to have an ACE account established prior to submitting Form 4811.

If you are the Importer of Record, refunds will be issued directly to your ACE account. You may authorize DHL to file a claim on your behalf or submit it independently.

Only tariffs imposed under IEEPA are eligible. All other applicable duties, fees, and tariff programs remain in effect and are not impacted by the Supreme Court’s ruling.

The information provided in this article is for general informational purposes only and is current as of the date of publication. Nothing contained herein constitutes, or is intended to constitute, legal, tax, customs, trade compliance, or other professional advice, nor does it create any advisory, fiduciary, or professional relationship between DHL Express and any reader or recipient. While reasonable efforts have been made to ensure the accuracy and completeness of the information presented, DHL Express makes no representations or warranties, express or implied, regarding the accuracy, completeness, reliability, timeliness, or suitability of any information contained in this article. Laws, regulations, policies, and procedures related to IEEPA tariff refunds, U.S. Customs and Border Protection (CBP) processes, the ACE Portal, and the CAPE system are subject to change at any time without prior notice. Eligibility for refunds, claim requirements, processing timelines, and outcomes are determined solely by CBP, the U.S. Treasury, and applicable U.S. laws and regulations, and are beyond the control of DHL Express.

DHL Express does not guarantee refund eligibility, approval, amounts, or timing, and shall not be liable for any loss, damage, cost, or expense (including but not limited to lost profits, penalties, or interest) arising from or in connection with any reliance on the information provided herein, any actions taken or not taken based on this article, or any decisions made by CBP, the U.S. Treasury, or other government authorities. References to third-party systems, portals, or processes—including the ACE Portal and CAPE system—are provided for informational convenience only; DHL Express does not control, operate, or assume responsibility for the availability, functionality, or accuracy of such systems. Readers should not act or refrain from acting based solely on the information in this article. Importers and other interested parties are strongly encouraged to consult with a licensed customs broker, qualified trade compliance specialist, or legal advisor regarding their specific circumstances before making any decisions related to tariff refund claims. Any use of DHL Express services or assistance with refund claims remains subject to applicable DHL terms and conditions, service agreements, and governing law.