Update: Progress On Tariff Refunds And New Legal Challenges

On Thursday, March 12, 2026, the U.S. Court of International Trade (CIT) scheduled an April 10 hearing to consider challenges brought by states and importers regarding the legality of the Section 122 global tariffs (link available here). 

On the same day, U.S. Customs and Border Protection (CBP) filed a declaration with the Court of International Trade outlining its plan to process tariff refunds under the International Emergency Economic Powers Act (IEEPA). As part of this effort, Customs and Border Protection is developing a new claims portal within its Automated Commercial Environment (ACE) system, called the Consolidated Administration and Processing of Entries (CAPE), to facilitate refunds of additional ad valorem duties imposed under IEEPA.

Customs and Border Protection is designing the Consolidated Administration and Processing of Entries with four integrated components: 

• Claim Portal 
• Mass Processing
• Review and Liquidation/Reliquidation
• Refund

Important takeaways: 

• Importers and customs brokers will use a Consolidated Administration and Processing of Entries online portal in the Automated Commercial Environment to submit claims in CSV format. 
• Consolidated Administration and Processing of Entries will run automated checks on submitted entries, remove IEEPA-related Harmonized Tariff Schedule provisions, recompute the duties owed, and then carry entries through liquidation or reliquidation as needed.
• Following the competition, overpaid IEEPA amounts will be refunded via electronic payment to the bank account on file for the importer.
• Customs and Border Protection indicates that different Consolidated Administration and Processing of Entries components are currently partially built (about 40%–80% complete) and will be deployed in stages, with simpler refund scenarios addressed first and more complex cases added over time.
• The full refund process could be extended for several months. 

Latest update: Customs reported that development is approximately 70% complete for the claims portal, 40% for the claim processing function, 80% for the liquidation/reliquidation component, and 60% for the refund component. The portal will initially launch with basic features and expand its functionality over time. In a March 19 filing, these figures were slightly higher at 73% (+3), 45% (+5), 80% (unchanged), and 63% (+3).

To read the Customs and Border Protection Court Filing, click here.

The RV Industry Association will continue to provide information as it becomes available. For a comprehensive overview of tariffs currently enacted, view the tariff tracker. Please contact Samantha Rocci, Director of Federal Affairs (srocci@riva.org) with questions or for more information.