Who Gets the Tariff Refund? Not Always Whoever Paid It

Key takeaways

• The refund doesn't follow your money. It follows a name on a customs document filed months ago. CBP's guidance is narrow: "CBP is only able to refund IEEPA duties to the Importer of Record or the Notify Party (designated on CBP Form 4811) who have their U.S. bank account information in their ACE Portal account." If the duty came out of your margin but someone else was the importer of record, that sentence is about them, not you.
• Most of the advice you'll find starts at the wrong gate. "Set up your ACE Portal, add your bank details" is real and necessary — but it's gate three. Gates one and two are was an entry even filed and whose importer-of-record number was on it. You cannot fix those now; they were settled at clearance.
• "You need a US bank account" is incomplete. CBP's own ACE FAQ describes what a foreign importer does if it "chooses not to maintain a U.S. bank account": designate a US customs broker as an authorized notify party. That's not an exemption — it's a channel swap. Your money lands in the broker's account first.
• Some parcels never had an entry at all. In a live case at the Court of International Trade, a judge asked a postal-duty intermediary five pointed questions on July 10, 2026; the answer filed on July 16, 2026 said "no entry, informal or otherwise, is prepared for the postal shipments" it collected duty on. Where there's no entry, there's nothing for a refund declaration to list.
• The pile of stuck refunds is growing — and it has reached the bench. CBP's sworn declarations put refunds that can't be transmitted for want of bank details at 8,384 as of June 29, 2026 and 9,837 as of July 10, 2026. On July 15, 2026 the court quoted that second number back and "urges CAPE declaration filers to ensure that their ACH account information has been provided to Customs so that their refunds may be disbursed." When a federal judge is reminding importers to fill in a form field, it isn't a formality.

Who gets the tariff refund? The importer of record — or the Form 4811 notify party

The short answer: CBP sends the refund to the importer of record on the entry, or to the notify party that importer designated on CBP Form 4811 — and to nobody else. Paying the duty economically does not put you on that list.

This is CBP's answer in its own words. Asked directly whether it sends refunds to consumers who paid more because of an IEEPA duty, CBP's IEEPA Duty Refunds page says (FAQ updated 5/20/2026):

"CBP is only able to refund IEEPA duties to the Importer of Record or the Notify Party (designated on CBP Form 4811) who have their U.S. bank account information in their ACE Portal account."

And on eligibility (FAQ updated 4/10/2026):

"The IOR or the party designated by the IOR (the 4811 notify party) on either the CBP Form 4811 (Special Address Notification) or on the ACE Portal account, and on the entry summary will be eligible to receive refunds."

Even the act of asking is gated the same way:

"Only the IOR for the listed entries or the authorized customs broker that filed the entries on behalf of the IOR may file the CAPE Declaration."

Why any of this exists: on February 20, 2026, the Supreme Court decided Learning Resources, Inc., et al. v. Trump (No. 24-1287, consolidated with No. 25-250, Trump v. V.O.S. Selections, Inc.), argued November 5, 2025. The holding is one line — "IEEPA does not authorize the President to impose tariffs" (slip opinion) — and it reached the tariffs imposed on that authority: the reciprocal and drug-trafficking tariffs, levied under the International Emergency Economic Powers Act. Giving that money back is a separate machine, and it has its own name: CAPE, the Consolidated Administration and Processing of Entries, which CBP runs inside ACE — the Automated Commercial Environment, the system your customs entries live in. (This decision is about IEEPA-based tariffs; duties imposed under other authorities are a separate question — the Section 122 surcharge among them — which we take apart in our brief on the Section 122 surcharge and what's lined up behind it.)

Here's the part almost nobody sequences for you. Between "IEEPA tariffs were struck down" and "money in your account" there are four gates, in this order, and each one has already been answered by a document you may not have read:

Gate 3 is where the internet starts. Gates 1 and 2 are where your answer usually is.

Were you the importer of record? The paperwork already answered

The importer of record is the party named on the entry as legally responsible for the declaration and the duty. That's not a role you elect after the fact, and it isn't decided by whose bank account the money left.

Notice what CBP's filing rule quietly does: only the IOR, or the authorized customs broker that filed the entries on the IOR's behalf, may file the CAPE Declaration. That means the mechanism itself answers the question for you. If neither you nor a broker acting for you can file a declaration listing those entries, the paperwork has already told you that you were not the importer of record — you were the party that paid for one.

So the useful move isn't to hunt for a claim form. It's to establish, for the entries in question, whose IOR number appears on the entry summary. The party that filed the entry — your broker, or the brokerage arm of whoever carried your goods — holds that record and can tell you. Whatever comes back is the answer; it isn't negotiable at this stage.

Two corollaries founders trip on:

• "I paid the tariff" and "I was the importer of record" are different sentences. They're often true of the same business. When your goods moved under an arrangement where someone else cleared them, they come apart — and the refund follows the second sentence.
• This is about entries filed while IEEPA duties were being collected, before the February 20, 2026 decision. How you ship today doesn't change who was named on a clearance last autumn.

If you sold DDP or through a marketplace

This is where the two sentences most often come apart.

DDP — Delivered Duty Paid — is an Incoterm. It's a term of your contract with the buyer, allocating who bears the cost and risk of import duty. It is not a CBP designation, and it does not, by itself, name anyone importer of record. Who the IOR is, is determined by the entry that gets filed. Those two things are related in practice and independent in law.

What follows is a caution, not a conclusion: when your goods moved DDP through a carrier's or broker's brokerage, that party's name can be the one on the entry — meaning it, not you, is the party CBP recognizes for a refund, even though the duty was economically yours. It often works that way; it does not always. The way to know is gate 2 — your entry summary, or the party that filed the entry: whose IOR number was on it.

The same caution extends to platform-arranged clearance. If a marketplace or its shipping program handled the customs side, the entry may name the program's carrier or broker. And watch the calendar here, because it decides whether a platform rule is even relevant to your refund: a mandatory platform DDP regime that took effect in July 2026 governs how you ship now — it postdates the February 20, 2026 decision entirely, so it has nothing to say about the entries a refund would cover. (We keep the platform-side DDP mechanics in our brief on a marketplace DDP mandate.)

If your question is the forward-looking one — for my next shipment, should I be the importer of record, should the buyer, or should a broker run a DDP flow? — that's a different decision with a different answer, and we lay it out in our brief on the end of de minimis and the new postal entry process. This brief is about the entries behind you, not the ones ahead.

If you shipped by post, there may be no entry at all

Gate 1 sounds like a formality. In the postal lane it isn't, and a federal court is working through exactly this question right now.

In Euro-Notions Florida, Inc. v. United States (Court of International Trade, Court No. 25-00595), Judge Richard K. Eaton wrote to counsel for Zonos on July 10, 2026, before ruling on its request to file as amicus, and asked five questions (ECF 44). They read like someone testing whether the standard vocabulary fits:

"Does your client have an importer of record identification number(s)?"

"Does your client in some way handle informal entries? If so, how?"

"Do you or does U.S. Customs and Border Protection have a record of any estimated duties or actual duties paid? What do those records consist of?"

The answer was filed on July 16, 2026 (ECF 47). Read it with the right label attached: Zonos (iGlobal Exports, LLC) is not a neutral commentator here — it is the party seeking to be heard in the case, describing its own operation. What makes it worth your attention is not its reading of the regulations but the fact of the statements themselves, made under a judge's direct questioning.

It opens by telling the court that the vocabulary doesn't fit: the terms "'importer of record,' 'estimated deposits,' and 'informal entries' do not map cleanly onto that mechanism." On whether it has an IOR number, the answer is a qualified yes that lands as a no — it submitted a CBP Form 5106 as part of a Qualified Party certification, but "this number is not associated with, and has never been used on, any entry filed with CBP, and Zonos has not been designated 'importer of record' within the meaning of 19 C.F.R. Part 141 on any transaction." On informal entries, the answer is flatly "No. … no entry, informal or otherwise, is prepared for the postal shipments on which Zonos collected and paid duty during the relevant period."

The described mechanism explains why. Duty for a month's postal shipments is aggregated on a monthly International Mail Duty Worksheet (IMDW) — a spreadsheet listing each shipment's tracking number, country of origin, duty rate, value, and duty owed — transmitted to CBP by the 7th of the following month, with the total remitted through Pay.gov. In its words: "No entry, formal or informal, is filed in ACE or otherwise for any individual shipment." The Qualified Party certification it operated under (CSMS # 65990231, Aug. 21, 2025) required a Form 5106 and a bond under 19 C.F.R. § 113.62 — and, per the filing, "it did not require, and does not reference, 'importer of record' status."

Put that next to gate 1. A CAPE declaration lists entries. If duty on your parcel was paid as a line on a monthly worksheet rather than through an entry, there is no entry to list — and the refund architecture, which runs on the importer of record of an entry, has nothing to attach to. None of this is hidden; the parties involved describe the mechanics publicly. What's new this week is that a judge is asking the questions in a live case, on the record.

And here's the timing that stings. IEEPA duties were collected in the postal lane from August 29, 2025 until the February 20, 2026 decision — a window in which, by this account, no IOR was designated on those shipments. An entry frame arrives in that lane on July 24, 2026, one week from today, under 91 FR 37,801, which limits the new postal informal entry process:

"The process for filing under this new postal informal entry process is limited to parties with the right to make entry under 19 CFR 143.26(a), that is, an owner or purchaser of the merchandise being mailed to the United States, or a licensed customs broker appropriately designated by the owner, purchaser, or consignee."

The rule is candid about what it's replacing. Before it, "The duties were allowed to be paid by carriers or qualified parties. So far, only qualified parties have submitted the international mail duty worksheets needed to calculate duties, and all qualified parties have chosen to pay using the ad valorem method." Afterward, its own economic analysis expects the change to bite: "The rule requires that parties submitting IMDWs to CBP be the owner, purchaser, or duly appointed licensed customs brokers. As a result, clients that have been using non-broker qualified parties to submit IMDWs will switch to using brokers …"

A second wave follows in the same lane. CBP will begin a test of a new electronic postal informal entry — entry type 13 — and its notice (91 FR 38,007) states that "The test will commence on September 22, 2026 and will continue until concluded by an announcement published in the Federal Register." The notice then names, almost exactly, the parties that had been paying postal duty without ever being an importer of record:

"The right to make entry, and thus to file an entry type 13, is limited to an owner or purchaser of the merchandise being mailed to the United States, or a licensed broker properly appointed by the owner, purchaser, or consignee. A consignee who is not an owner or purchaser, such as a foreign postal operator, USPS, a freight forwarder, or a carrier, must obtain the services of a licensed broker who will act as the importer of record (IOR) for the entry."

Read that against the court filing above and the shape of the problem is obvious. The postal lane's whole difficulty is that duty was paid by parties that weren't the importer of record on those shipments — so when the money had to come back, there was no one for it to come back to. From July 24, 2026, and again in the September test, that lane is rebuilt so that someone always is. (The bonds, worksheets, and timelines of both sit in our de minimis brief; what matters here is the direction of travel.) Going forward, a postal shipment will have a name attached to it. The parcels that carried the refundable duty don't.

The US bank account question is downstream, not the gate

The advice you'll find most often on this topic is that a US bank account is mandatory to receive a tariff refund. It's the right thing to say at gate 3, and it's incomplete.

The mandatory part is real. CBP's refunds page is unambiguous:

"You must have your U.S. bank account information in your ACE Portal account. With rare exceptions, all refunds will be made through a secure ACH payment to a verified party, not through a paper check disbursed through the mail to a non-verified address."

There's no side door around the portal itself — "Can I still get a refund if I don't have an ACE Portal account? — No." And a refund CBP has calculated but can't send doesn't fail loudly; it just stops: "If you have not updated your ACE Portal account with your current ACH information, you will not receive a refund. CBP will hold the refund until the ACH account information is available."

That holding pen has a size, and it's growing. In a sworn declaration by Brandon Lord, Executive Director of CBP's Trade Programs Directorate, filed in the Euro-Notions case (ECF 39):

"As of 3pm eastern time on Monday, June 29, 2026, 8,384 refunds have not been transmitted to Treasury because Automated Clearing House account information has not been provided by the importer of record or its authorized CBP Form 4811 designee."

His next declaration, filed July 13, 2026 with data as of 3pm ET on July 10, 2026, puts the same figure at 9,837. That's the number worth sitting with. Over the same eleven days, CAPE intake rose to roughly $121.75 billion accepted for processing, of which about $86.3 billion was completed, certified, and sent to Treasury. Tens of billions are moving — and the stack of unsendable refunds got bigger. These are refunds whose only stated blocker is a missing bank detail; CBP's own declaration attributes the non-transmission to nothing else. (Hold onto that number; it turns up again below, in a judge's order.)

Now the part the "you need a US bank account" version leaves out. CBP's ACE Portal and ACH Refunds FAQs answers the question "My client is a foreign importer. How do they meet the requirement to get set up for ACH refunds?" in two branches:

"If a foreign importer chooses to open and maintain a U.S. bank account, the importer can use their ACE Portal account to authorize ACH refunds."

"If a foreign importer chooses not to maintain a U.S. bank account, the importer can take the following steps to receive potential refunds: The importer can use their ACE Portal account to designate a U.S. Customs broker as an authorized notify party"

The broker side of that arrangement is spelled out too: "Can I act as a notify party and receive refunds via ACH on behalf of my importer client? — Yes. If a broker or other third party is authorized by an importer as a notify party, and if the broker is set up to receive refunds electronically, the authorized party may receive those refunds via ACH on behalf of the importer." A licensed broker with a valid power of attorney can authorize a notify party for a client and can email a CBP Form 4811 to the client's assigned Center of Excellence and Expertise; per CBP, "A power of attorney is not required when submitting a CBP Form 4811 but may be requested by the Center."

Read that as a channel swap, not an exemption. The words carrying the weight are "on behalf of." CBP's obligation ends when the money reaches a verified party — and in this route, the verified party is your broker. Whether it then reaches you is a matter of your contract with that broker, and CBP does not administer that leg. So the requirement hasn't been waived. It's been moved: from "do you have a US bank account" to "whose account is it, and what does your agreement say about money that lands there." For a non-resident business, that's a real option and a real exposure, and it deserves a conversation before the money moves rather than after.

Two mechanical traps sit in this same gate, and both produce silent failure:

• Your routing number has to be on FedACH. "CBP will reject bank information if the bank routing number does not process FedACH payments." CBP advises verifying this rather than assuming it.
• Foreign addresses have to be formatted correctly. CBP requires that foreign addresses stored in the Importer sub-account view be "properly formatted, according to the foreign country's address standards."

Two ACE reports exist precisely because these fail quietly: Rev-613 lists refunds rejected because ACH wasn't set up, and Rev-603 lists refunds returned by the bank. If you filed and heard nothing, those reports are where the silence gets explained.

One thing this brief deliberately won't re-explain: how a foreign-owned entity actually opens the US account in the first place — the beneficial-ownership check a bank runs at account opening is a separate regime with its own 2026 news, and we cover it in our brief on foreign-owned LLCs and US bank accounts.

Two clocks: 80 days, 90 days, and the part still in court

Gate 4 is the one that has already closed for millions of entries — and CBP's page states it with two different numbers.

Ninety days is the statute. 19 U.S.C. § 1501 gives CBP the authority to reliquidate an entry "in any respect by U.S. Customs and Border Protection, notwithstanding the filing of a protest, within ninety days from the date of the original liquidation" (text). That ceiling isn't theoretical: in CBP's declarations, "the entry date is past CBP's 90 day re-liquidation authority" is the first-listed reason entries fail. As of June 29, 2026, 4.36 million entries on CAPE declarations had failed entry-level validations, for that reason and two others — the entry lacks a Chapter 99 HTSUS number used to assess IEEPA duties, or it was already filed on a prior declaration. By July 10, 2026 that number was 4.77 million. Separately, the declarations covered 24.4 million entries that passed validation and were accepted for the removal of IEEPA duties — of which 16.74 million had by then been liquidated or reliquidated without them.

Eighty days is CBP's operational line, not the statutory one — § 1501's number is ninety. Its refunds page describes the current phase this way: "Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation." The Lord declaration uses the same framing, describing a June 29, 2026 update that lets in certain reconciliation-flagged entries that are unliquidated or that have "liquidated within the preceding 80 days." Elsewhere on the same page, a different FAQ describes Phase 1 as "limited to unliquidated entries or entries within the 90-day voluntary reliquidation period."

CBP does explain the ten-day difference — just not in the answer that sets the eighty-day line. Asked whether liquidated entries can go on a declaration, it says (FAQ updated 4/10/2026): "During Phase 1, ACE will accept CAPE Declarations containing entries liquidated within the preceding 80 days. This will allow sufficient time for CBP to process and reliquidate entries by the 90th day to meet the agency's legal timeframe for voluntary reliquidation pursuant to 19 U.S.C. § 1501."

So the ten days aren't slack. They're CBP's workbench — the processing time it carved out of the statute's ninety so that your reliquidation lands before the door closes. Which makes the practical implication sharper rather than softer: if your entry liquidated 85 days ago, you are inside the statute's ninety days and outside the eighty-day line, because CBP has decided it can't finish the work in the five that are left. Assuming those two numbers mean the same thing is how a live entry gets treated as dead — or a dead one gets planned around.

A third number floats through this topic and measures something else entirely: CBP says valid IEEPA refunds are "generally issued within 60 - 90 days following acceptance of the CAPE Declaration." That's how long payment takes after your declaration is accepted — a processing time, not an eligibility window. Three numbers, three meanings, one page.

For Phase 1, CBP is direct about litigation: "Specifically with respect to Phase 1, which is limited to unliquidated entries or entries within the 90-day voluntary reliquidation period, you do not need to file a case with the CIT to receive an IEEPA refund due to you. CBP offers no legal guidance on whether a case needs to be filed with the CIT for any other entries." Note what that second sentence does — it declines to answer the question everyone outside Phase 1 has.

Which brings us to the open part. On July 15, 2026, after a conference the previous day, Judge Eaton entered an order in the same case. Three things in it matter to a founder.

First, what's planned for entries past the ninety days. In connection with the anticipated launch of CAPE Phase 3, "development of which is ongoing, the court will enter an order that directs Customs to reliquidate certain finally liquidated entries in accordance with a procedure that will be outlined in the order." Then the sentence that defines its reach: "The order will be entered in each of the approximately 3,700 IEEPA cases assigned to the court." Read that precisely — that route runs through cases assigned to the court, which is to say through importers who filed suit.

Second, what that does not settle. It would be easy, and wrong, to read the previous paragraph as "if you didn't sue, you're out." The same order keeps another door open: the court will lift the stay in "Freestyle World, Inc. v. United States, Court No. 26-01088 … in which a motion for class certification is currently pending." It adds that "The schedule for Rule 23 hearings in Freestyle World, and in V.O.S. Selections, Inc. v. United States, No. 25-00066, was discussed as well," and notes discussion of further CAPE functionality to process refunds for "entries with open protests." A pending class-certification motion is exactly that — pending. This brief doesn't predict how it resolves, and you should be wary of anyone who does.

Third, a date for your calendar instead of a prediction. The order gives one: "ORDERED that Defendant shall file, by 5:00 p.m. EDT on Tuesday, August 4, 2026, a short report on the progress of CAPE." That's the next public checkpoint on this whole process — with a wrinkle worth knowing before you go looking for it. The same order adds that "Should this case be voluntarily dismissed before August 4, 2026, the Government shall file the report in Freestyle World, Inc. v. United States, Court No. 26-01088" — and it records, a page earlier, that Euro-Notions has told the court it intends to dismiss. So the report may well land on the other docket. Watch whichever of the two survives, rather than the headlines — and in the meantime, find out from your entry summary whether your entries are unliquidated, liquidated within the last 80 days, or finally liquidated, because that status determines which of these tracks is even yours.

And then, in the middle of an order about court procedure, the judge stops to talk about bank details:

"It is also worth noting that 9,837 refunds have not been transmitted to Treasury because Automated Clearing House ("ACH") account information has not been provided by the importer of record or its authorized designee. … The court urges CAPE declaration filers to ensure that their ACH account information has been provided to Customs so that their refunds may be disbursed."

That is the same 9,837 from the declaration above — now in a court order, with a federal judge urging importers to go fill in a form field. Nothing in that passage is about tariff law. The tariff-law question — whether IEEPA authorized these tariffs at all — was settled on February 20, 2026. What's still stopping the money in July is documents and account details.

What to do now

In order, because the order is the whole point.

1. Establish whether an entry exists, and whose IOR number is on it. Gates 1 and 2, and everything downstream is wasted effort until you have the answer. Ask the party that filed the clearance. If your goods moved by post through a duty-aggregation arrangement, ask specifically whether an entry was filed at all.

2. If you were the IOR, the declaration goes in ACE — by you or by the broker that filed the entries. That's the only route, and CBP is emphatic about it because of what's circulating around it (see step 4).

2b. If someone else was the IOR, your counterparty isn't CBP — it's them. Ask the party that cleared your goods what it is doing about the refund on those entries, and read what your contract says about duties it collected from you. CBP's own eligibility sentence contemplates someone other than the importer of record receiving the money — the Form 4811 notify party — but that designation is the IOR's to make, not yours to claim, and CBP does not administer what happens after the money lands. Treat this as a commercial conversation with a deadline attached, not a filing.

3. Fix the gate you can actually move: ACE Portal plus ACH. No portal account, no refund. Confirm the routing number processes FedACH — CBP rejects the ones that don't. If your address in the Importer sub-account is foreign, make sure it's formatted to that country's standards. Then check Rev-613 and Rev-603 rather than waiting: they're the reports that tell you a refund was rejected for missing ACH or bounced back from the bank. This is the step a federal judge publicly urged CAPE filers to take on July 15, 2026 — when the bench is reminding people about their bank details, treat it as the live failure mode, not a formality. If you're a foreign importer without a US account, the notify-party route through a US customs broker exists — go in with the contract question settled, since CBP's job ends when the money reaches your broker.

4. Treat unsolicited refund help as hostile. In early July 2026 — CBP's site lists the page as last modified July 7, 2026 — CBP published a fact sheet (Publication # 5619-0792) warning that it "is witnessing an increasing trend of suspicious mailers, flyers, and notices being sent throughout the trade community." The line to memorize:

"Submitting your CAPE Declaration in ACE is the only way to submit a request for an IEEPA refund. Do not provide any information on any website that claims to process IEEPA refunds if it is not the ACE Portal."

CBP adds that it "will generally not request sensitive information to process IEEPA refunds, such as Social Security numbers, bank account details, or passwords via email or text message." Its official email domains are @cbp.dhs.gov and @associates.cbp.dhs.gov, and suspected fraud goes to IEEPAFraud@cbp.dhs.gov. Its listed warning signs: "Requests for personal or financial information / Offers of refunds in exchange for data / Unsolicited emails, calls, or texts / Pressure to act quickly / Poor grammar, spelling errors, or suspicious links in solicitation emails." Two of those deserve a founder's attention. "Pressure to act quickly" is the hard one, because the clocks in the previous section are real — which is exactly what makes manufactured urgency sound credible. And an offer to "recover your refund for a fee" collides with CBP's own statement that "CBP does not charge any fees for processing tariff refunds." The cruel logic here is worth naming: the people most exposed to these offers are the ones who can't file — the ones who paid the duty but weren't the importer of record. If that's you, no third-party service can make you the importer of record. That gate closed at clearance.

5. Set expectations for what actually arrives. Accepted declarations generally pay out in 60–90 days. Interest is included, governed by 19 U.S.C. § 1505; per CBP, "The rate of interest is determined by the IRS and published quarterly in the Federal Register." And what lands can be smaller than what you're owed — CBP says CAPE refunds are subject to "the netting of all over- and under-payments for the entire entry, as determined at liquidation or reliquidation" (it points to 19 C.F.R. § 159.1), and to "the potential diversion of refunds as necessary and appropriate to offset the importer's legally fixed and undisputed unpaid debts to the United States" (19 C.F.R. § 24.72).

It can also go the other way, which is the part worth bracing for. Asked "Can my CAPE Declaration result in a bill?" CBP answers: "Yes, at least for entries in Phase 1." Stripping the IEEPA duties off an entry doesn't strip off everything else it owes — "entries are still subject to any duties, taxes, and fees, including pursuant to other trade remedy provisions, that are applicable upon liquidation or reliquidation." A refund is a settlement of your account, not a transfer.

6. Then fix the layer this whole episode keeps pointing at. Notice what every gate above has in common. CBP will send money "through a secure ACH payment to a verified party, not through a paper check disbursed through the mail to a non-verified address." Your ACE activation runs through an email address that CBP wants tied to "your company's physical address in the Importer (5106) record, as opposed to its mailing address." Your foreign address has to be formatted to a standard. Your address isn't the payment rail — the money moves by ACH to a verified party. What the address decides is whether the records that gate that payment agree with each other: the 5106 email CBP wants tied to your physical address, the foreign address it requires formatted to standard, the account it will only pay to a verified party.

That's the unglamorous infrastructure underneath a lot of founder problems, and it's the part software doesn't solve for you — a theme we've written about in what a one-person company still can't automate. To be precise about what an address is and isn't here: a business address is not a customs address, and it does not make you an importer of record. What it does is make your records agree with each other, and make you findable when a government system has something for you. On the US side, our partner SaveOffice runs that service — Auteur doesn't operate the US service directly. If your records currently point at a home address, an old address, or three different addresses, set up a US business address through our partner before the next system needs to reach you.

This is general information about a customs and trade development for founders, not legal, tax, or customs advice — confirm the specifics for your entries and situation with US Customs and Border Protection or a licensed customs broker before you rely on it.

FAQ

How to claim IEEPA tariff refund? You file a CAPE Declaration in ACE — and per CBP, that's the only route: "Submitting your CAPE Declaration in ACE is the only way to submit a request for an IEEPA refund." But eligibility to file is restricted: "Only the IOR for the listed entries or the authorized customs broker that filed the entries on behalf of the IOR may file the CAPE Declaration." You also need an ACE Portal account with US bank information for ACH — "Can I still get a refund if I don't have an ACE Portal account? — No." CBP charges nothing for this: "CBP does not charge any fees for processing tariff refunds." For Phase 1, CBP says "you do not need to file a case with the CIT to receive an IEEPA refund due to you."

Are IEEPA tariffs being refunded? Yes, and at significant scale. CBP's sworn declaration in Euro-Notions Florida, Inc. v. United States, with data as of 3pm ET on July 10, 2026, reports roughly $121.75 billion accepted for processing in CAPE, of which about $86.3 billion was completed, certified, and sent to Treasury. The caveat is the queue behind it: 9,837 refunds had not been transmitted because ACH account information hadn't been provided by the importer of record or its authorized Form 4811 designee — up from 8,384 as of June 29, 2026. The court quoted that figure in a July 15, 2026 order and "urges CAPE declaration filers to ensure that their ACH account information has been provided to Customs so that their refunds may be disbursed."

Will importers get tariff refunds? Many will; many won't, and the split is mostly mechanical. As of July 10, 2026, 4.77 million entries on CAPE declarations had failed entry-level validations — the first-listed reason being that "the entry date is past CBP's 90 day re-liquidation authority," along with entries lacking a Chapter 99 HTSUS number used to assess IEEPA duties or already filed on a prior declaration. Separately, 24.4 million entries were accepted for the removal of IEEPA duties, 16.74 million of them already liquidated or reliquidated without those duties. For finally liquidated entries, the court said on July 15, 2026 that in connection with CAPE Phase 3 it "will enter an order that directs Customs to reliquidate certain finally liquidated entries," and that "The order will be entered in each of the approximately 3,700 IEEPA cases assigned to the court" — a route running through importers who sued. Whether relief reaches importers who didn't sue isn't settled: a motion for class certification is currently pending in Freestyle World, Inc. v. United States, Court No. 26-01088. The next public checkpoint is a CAPE progress report the government must file by 5:00 p.m. EDT on August 4, 2026.

Who is eligible for tariff refunds? In CBP's words: "The IOR or the party designated by the IOR (the 4811 notify party) on either the CBP Form 4811 (Special Address Notification) or on the ACE Portal account, and on the entry summary will be eligible to receive refunds." Bearing the cost isn't the test — CBP, answering whether it sends refunds directly to consumers who paid more because of an IEEPA duty, said it "is only able to refund IEEPA duties to the Importer of Record or the Notify Party (designated on CBP Form 4811) who have their U.S. bank account information in their ACE Portal account." If you sold DDP or a platform's program cleared your goods, the entry may name someone else — which is why gate 2 comes before any advice about bank accounts.

Bottom line

The tariff refund follows the paperwork, not the payer. CBP pays the importer of record on the entry, or the notify party that importer designated on Form 4811 — and it pays by ACH to a verified party, or it doesn't pay. That means the decisive fact about your refund was recorded months ago, at clearance, in a document you probably never read, and no amount of portal setup changes it.

Which is why the order matters more than the checklist. Was there an entry? In the postal lane, possibly not — a judge asked that question on July 10, 2026 and got "no entry, informal or otherwise" back on July 16, 2026. Whose name was on it? If your goods moved DDP or through a platform's program, plausibly not yours. Only then does the bank-account question — the one the internet leads with — become your question. And even there, "you need a US bank account" isn't quite the rule: CBP describes a broker notify-party route for foreign importers who choose not to maintain one, which relocates the requirement rather than removing it.

There's an irony sitting one week out. On July 24, 2026, the postal lane finally gets an entry structure built on owners, purchasers, and licensed brokers — with a September test that spells out that a carrier or postal operator "must obtain the services of a licensed broker who will act as the importer of record (IOR) for the entry." It arrives about five months after the tariffs it might have documented stopped being collected. Going forward, those parcels will have a name on them. The money already paid won't.

So skip the predictions. Put August 4, 2026 — the government's next CAPE progress report — in your calendar, find out from your entry summary whether your entries are unliquidated, recently liquidated, or finally liquidated, and fix the one gate that's still yours to move. A federal judge spent a paragraph of a court order this week telling importers to go check their bank details. That is what this whole episode is really about: the law can be settled in your favor and the money still won't move, because it travels on documents and account details rather than on being right. Be a verified party, at a verified address, in the systems that owe you money — before they have something to send.