US requires importer of record to file struck-down tariff refund claims
Tariff refund claims proceed only through the original importer-of-record chain
Change
US agencies opened a tariff-refund process in late April 2026 requiring refund claims for struck-down tariff payments to be filed electronically by the original importer of record through CBP’s ACE Secure Data Portal.
Why it matters
The filing route is tied to the original importer-of-record record, not to any replacement broker or consultant. The first phase limits claims mainly to entries liquidated within the past 80 days and requires a digital file listing eligible entries. Refunds paid in 2026 are taxable where the related tariff costs were deducted in 2025.
Implications
- — Importers seeking refunds must route claims through the original importer of record via ACE Secure Data Portal — claims filed through another broker or consultant do not proceed.
- — Customs brokers acting as importer of record must upload the Consolidated Administration and Processing for Entries Declaration file listing eligible entries — refund submissions without the required file remain incomplete.
- — Import tax and accounting teams receiving 2026 refunds must tax-match refunds against tariff deductions taken in 2025 — deducted prior-year tariff costs make the refund taxable.
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