Tariffs and Supply Chain

IEEPA Refund Roadmap

Following the Supreme Court’s ruling in Learning Resources, Inc. v. Trump, the administration's IEEPA-based tariffs are unlawful. CPMA is tracking the Customs and Border Protection (CBP) CAPE (Customs Automated Processing Environment) portal development.

How to Recover IEEPA Tariffs

• Eligibility: Any IEEPA duties paid on entries from 2025 through Feb 2026.
• The Process: Importers must prepare spreadsheet summaries of entries for the CAPE e-filing portal.
• Mandatory Enrollment: To receive any IEEPA refunds, companies must have an active ACE (Automated Commercial Environment) Secure Data Portal account and be enrolled in the ACH Refund program.
  - U.S. Bank Account: The system requires a U.S. bank account. If your company is a foreign-based importer, you must either establish a U.S. account or formally designate a third party (like your customs broker) who has one to receive the funds on your behalf.
• Create or ensure your customs broker has an ACE (Automated Commercial Environment) account.
  -If the ACE resides with your customs broker, you must have an Importer Portal Account to maintain direct control over your financial and legal obligations.
• Current Status: CBP is currently finalizing the CAPE (Consolidated Administration of Processing of Entries) portal. Once live (estimated mid-Q2 2026), you will use this ACH-linked account to claim your specific refunds.
• Pro-Tip: Check if your entries have "liquidated." Unliquidated entries may be processed faster via Post-Summary Corrections (PSC).

Supply Chain Resilience

We monitor geopolitical and environmental "Black Swan" events that threaten the flow of pigments and raw materials.

• Geopolitical Volatility: Continued tensions in the Middle East (Iran/Red Sea) are impacting freight insurance and transit times for organic pigment intermediates.

Disclaimer: The information provided on this page is for general informational purposes only and does not constitute legal, financial, or customs advice. While CPMA strives to provide accurate and timely updates regarding tariffs, supply chain disruptions, and refund processes, trade regulations are subject to rapid change. CPMA makes no warranties or guarantees concerning the completeness or accuracy of this data. Those viewing this site should consult with their own licensed customs brokers, legal counsel, or trade compliance professionals before taking action based on the information provided herein.