On March 4, Judge Eaton of the Court of International Trade issued a nationwide permanent injunction directing that all importers who paid IEEPA tariffs are owed full refunds. For entries that had already been liquidated, CBP may also owe interest.

Penn-Wharton estimates between $166 billion and $179 billion in IEEPA duties were collected. CBP's own figures put 53 million entries across 330,000+ importers in scope.

That's the good news.

The bad news: there's a process, it has a hard launch date, and most of your clients haven't taken the first step.

---

The April 20 Deadline

CBP is building a new refund processing system called CAPE — Consolidated Administration and Processing of Entries. Phase 1 of CAPE launches April 20, 2026.

Phase 1 covers approximately 63% of eligible entries: specifically, entries that are currently unliquidated, or that were liquidated within the last 80 days. Older liquidated entries will be addressed in later phases, but no timeline for those phases has been confirmed.

Here's the problem: importers must be registered in CBP's ACE portal with verified ACH banking information before Phase 1 launches. Importers who are not enrolled when the system goes live will have their claims placed in rejected status.

As of March 26, only 26,664 of 330,000+ eligible importers had completed enrollment. That's fewer than 8%. Those enrolled importers happen to represent 78% of affected duties by dollar value — large importers with trade compliance teams moved quickly. But the remaining 92% of importers by count, likely including the smaller businesses that are your clients, have not registered.

CBP discontinued paper checks earlier this year. ACH is the only refund method. If an importer's ACH information is not in the system, there is no alternative.

---

Who Qualifies

The claim is the Importer of Record's to make. Only the company or individual listed as the Importer of Record on the original customs entry documentation can initiate a Phase 1 claim. Third parties who may have been reimbursed for tariff costs by their suppliers must pursue those recoveries separately, through contract.

For Phase 1 specifically, eligible entries are:

• Unliquidated entries — entries where CBP has not yet issued a final determination of duties owed
• Entries liquidated within the last 80 days — entries where final duty assessment occurred recently enough to fall within Phase 1 scope

If you are not sure whether a client's entries qualify for Phase 1 specifically, their customs broker can confirm liquidation status.

Once claims are submitted through the CAPE portal, CBP has up to 45 days to review and process them.

---

The Three-Step Action Plan for Accounting Firms

You don't need to become a customs specialist to help your clients with this. The action items are finite and achievable before April 20.

Step 1: Identify which clients are affected

Pull your client list and flag any client that imports goods into the United States. Look for:

• Clients with freight or import duty line items in their financials
• Clients whose cost of goods includes customs charges
• Clients who work with customs brokers
• Clients in manufacturing, wholesale distribution, retail, or any product-based business

The Importer of Record is the entity listed on CBP Form 7501 (Entry Summary). If you have access to your clients' trade documentation, this is where to look. If not, your client's customs broker has this information.

Step 2: Check ACE enrollment status

Ask each affected client two questions:

1. Do you have an active account in CBP's ACE portal?
2. Is your ACH banking information entered and verified in that account?

If they don't know what ACE is, they almost certainly haven't enrolled. That's the majority of smaller importers right now. This is a registration process, not a legal filing — there is no attorney required to complete it.

Clients can register at cbp.gov using the ACE portal application guide CBP has published. The process requires basic business information and banking details for ACH setup.

Step 3: Help them organize their entry data

The CAPE claim portal will require importers to identify the specific entries for which they are claiming refunds. That means gathering:

• Entry numbers (from customs entry documentation or their customs broker)
• Import dates
• Ports of entry
• IEEPA duty amounts paid per entry
• Liquidation status for each entry

As their accountant, you may already have the financial records that contain this information. Matching duty payments to individual entry numbers is a data organization task — exactly the kind of work accounting firms do well.

Do not attempt to compile this from scratch without involving the client's customs broker. The broker holds the entry documentation and can cross-reference CBP records directly.

---

Why This Is an Advisory Opportunity, Not Just a Task

Your clients who are importers have been paying elevated costs for the last year or more under IEEPA tariffs. Many built those costs into their pricing, absorbed them into margins, or passed them through to customers. The refund doesn't undo all of that — but it returns the duty principal, and potentially interest, for entries that qualify.

For a mid-size manufacturer or distributor that paid $200,000 or $500,000 in IEEPA duties, this is a material recovery. They need someone to tell them it exists, explain what to do, and help them get organized before the deadline.

That's you.

The accounting firms that call their importer clients this week — before April 20 — will be remembered as the advisors who protected their clients' money. The ones who don't make that call will be explaining later why they didn't flag a $166 billion refund program before the registration window closed.

This is also a concrete example of what proactive advisory looks like. Not "we prepare your returns." Not "we're available when you have questions." You called. You knew. You acted. That's the firm that retains clients and earns referrals.

---

What to Do This Week

Today or tomorrow:

• Pull your client list and identify importers of record
• Send a one-paragraph email or make a phone call to each affected client flagging the April 20 deadline

By April 15:

• Confirm ACE enrollment status for each affected client
• Connect unenrolled clients with their customs broker to begin registration

By April 19:

• Verify ACH banking information is entered and current in each enrolled client's ACE account
• Confirm entry data is organized and ready for claim submission

After April 20:

• Monitor CAPE claim portal access for enrolled clients
• Assist with data entry for claim submission as the portal becomes available

The refund process itself will take weeks to months — CBP has up to 45 days per claim, and older liquidated entries will wait for later phases. But the registration window closes when Phase 1 launches. That part is now.

---

The Crossing Co covers what AI and policy changes mean for professional services firm owners in the US and Canada. If this was useful, subscribe to The Crossing Report — a weekly intelligence briefing for accounting, law, and consulting firm owners navigating the new landscape.