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ARTICLE · 29 APRIL 2026

Preparing For IEEPA Tariff Reimbursement Demands A Proactive Approach

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As US Customs begins processing IEEPA tariff refunds, companies face mounting pressure from customers demanding reimbursement of tariff costs that were passed through in pricing.

United StatesInternational Law
Peter Wolf
Peter Wolf
Stephanie Coirin
Stephanie Coirin
Matthew McConkey
Matthew McConkey
Timothy Keeler
Timothy Keeler
Jing Zhang
Jing Zhang
Sydney Mintzer
Sydney Mintzer
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The first phase of US Customs & Border Protection’s (“CBP”) Consolidated Administration and Processing of Entries (“CAPE”) refund system went live on April 20, 2026. This initial phase is limited to certain unliquidated entries and certain entries within 80 days of liquidation, and CBP is forecasting a 60-90 day refund period. Other refunds will commence at a later, unspecified time.

As the tariff landscape shifts focus to the refund process, companies across the supply chain are beginning to face reimbursement demands from customers seeking recovery/reimbursement of IEEPA tariff costs. The overall request is based on an assumption that, though the IEEPA tariffs were paid by the importer, the cost of the tariffs was either expressly or implicitly passed on to the customer through higher prices. Since these additional costs are now being refunded by CBP, certain customers are requesting that the importer agree to reimburse the applicable portion of the IEEPA refunds. Indeed, at least

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