IEEPA Tariff Refunds Worth Hundreds of Billions Set to Begin　PwC Urges Businesses to Seize Critical Refund Window

(Source: PwC Taiwan)

Following the U.S. Supreme Court's Feb. 20 ruling that tariffs imposed by the Trump administration under the International Emergency Economic Powers Act (IEEPA) lacked clear statutory authorization, significant progress has recently been made on the tariff refund process. U.S. Customs and Border Protection (CBP) has officially issued detailed refund procedures and system operation guidelines. The total amount of refunds involved is estimated to reach hundreds of billions of U.S. dollars, a development expected to have major implications for U.S. importers as well as related exporters in Taiwan.

According to the latest guidance issued by CBP, the U.S. will officially launch the Consolidated Administration and Processing of Entries (CAPE) system at 8:00 a.m. Eastern Time on April 20, 2026, to centrally process tariff refund claims arising from duties imposed under the IEEPA.

The new system will operate within the Automated Commercial Environment (ACE) customs platform and replace the previous case-by-case refund mechanism with a centralized filing and batch-processing model. Eligible importers will be able to consolidate refund applications through the ACE system, after which CBP will conduct centralized reviews and issue lump-sum refunds of the relevant duties, significantly improving administrative efficiency and reducing processing times for businesses.

The transition is widely regarded within the industry as a major milestone in the evolution of U.S. Customs operations from the traditional "transaction-by-transaction" approach toward a more systematic and centralized settlement framework.

Based on the information released to date, the first round of refunds will primarily apply to relevant entry filings that have not yet been liquidated, as well as those for which fewer than 80 days have elapsed since liquidation. Such cases must first undergo reliquidation by CBP, and, upon confirmation of duty overpayments, refunds will subsequently be processed through the CAPE system.

Taiwanese exporters that shipped goods to the U.S. during the period in which the IEEPA tariffs were imposed may, in principle, have an opportunity to obtain refunds where the U.S. importer of record is either their U.S. subsidiary or customer. Refund claims may be submitted in the name of the U.S. subsidiary, or exporters may indirectly benefit from such refunds through commercial negotiations with the importer regarding the allocation of tariff-related costs.

In practice, companies should pay close attention to the following matters:

1. Conduct a prompt internal review: Review exports shipped to the U.S. during the relevant period specified by U.S. authorities, particularly products subject to additional tariffs imposed pursuant to the IEEPA, together with the corresponding customs entry documentation.

2. Coordinate with U.S. importers: Confirm whether the importer has reviewed CBP's latest refund guidance and whether it intends to initiate a centralized refund application through the ACE/CAPE system.

3. Closely monitor filing deadlines and procedural requirements: Although CBP has released operational guidelines, under the phased refund framework the applicable filing periods, procedural requirements, and supporting documentation for each refund claim remain subject to official announcements. Companies should therefore closely monitor developments to avoid forfeiting refund eligibility due to missed deadlines.

4. Review contractual arrangements and tariff allocation mechanisms: Reassess existing contractual provisions relating to tariff liability, price adjustment mechanisms, and the allocation of refunded duties, and, where necessary, renegotiate such terms to safeguard the company's interests.

PwC Taiwan partner attorney of PricewaterhouseCoopers Legal Taiwan, Lee Yi-Chen, noted that for many Taiwanese companies, U.S. subsidiaries have historically served as the importer of record before products were subsequently delivered to U.S. customers. As such, pursuing tariff refunds may not only help recover costs previously incurred as a result of increased duties, but also reflects a broader shift in the U.S. toward placing greater emphasis on due process and clear statutory authority when balancing trade remedies against the President's exercise of emergency economic powers. Going forward, companies planning U.S. investment and export strategies should closely monitor developments in U.S. tariff laws and trade policy trends in order to mitigate potential risks.

In addition, given the complexity of the practical procedures involved in applying for IEEPA tariff refunds, companies are advised to work closely with professional advisors to accurately assess refund eligibility and application strategies on a case-by-case basis. Doing so may help businesses maximize the cost-saving opportunities arising from the launch of the new system.

About PwC Taiwan

PwC Taiwan is the Taiwan member firm of the global PwC network. Its purpose is to "build trust in society and solve important problems." PwC is a technology-enabled and people-focused global network operating in 136 countries with more than 364,000 professionals dedicated to delivering high-quality audit and assurance, tax and legal, deals, and consulting services.

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PwC Taiwan provides integrated, one-stop professional services across six cities in Taiwan, with a workforce of more than 4,000 professionals. For more information, please visit the PwC Taiwan website at www.pwc.tw