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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On March 6, 2026, Brandon Lord, a U.S. Customs and Border Protection (CBP) official who, inter alia, leads CBP&rsquo;s strategic efforts to enforce and protect tariff revenue, submitted a <a href="https://storage.courtlistener.com/recap/gov.uscourts.cit.19346/gov.uscourts.cit.19346.31.0_1.pdf" target="_blank" rel="noreferrer noopener">declaration</a> to the U.S. Court of International Trade outlining a proposed process for issuing refunds for importers who have paid tariffs under the International Emergency Economic Powers Act (IEEPA). The proposal, the first tendered by the agency, envisions a new mechanism to pursue refunds on the Automated Commercial Environment (ACE), CBP&rsquo;s portal for processing, collecting, refunding, and recording tariffs. Although the precise contours of this mechanism remain unclear&mdash;even the declaration acknowledges that &ldquo;operational, legal, and technical considerations may require alterations or modifications&rdquo;&mdash;the declaration indicates that the new functionality could be deployed within approximately 45 days and would require &ldquo;minimal submission from [affected] importers.&rdquo; For additional background on the declaration and the proposed ACE functionality, see <a href="https://www.thompsonhinesmartrade.com/2026/03/cit-suspends-earlier-order-directing-ieepa-tariff-refunds/">Update of March 6, 2026</a>.
The declaration identifies two steps importers should take now to facilitate the receipt of IEEPA tariff refunds.
<h2 class="wp-block-heading">1. Enroll in the ACH Refund Program on ACE</h2>
Importers should confirm they are enrolled in CBP&rsquo;s Automated Clearing House (ACH) Refund Program, which allows CBP to issue&mdash;and importers to receive&mdash;refunds electronically.
To enroll, importers must submit an application through the ACE and designate a U.S. bank to receive refund payments. Importers already enrolled do not need to reapply and will continue receiving refunds electronically without interruption.
Enrollment in the ACH Refund Program is particularly important because, as of February 6, 2026, CBP transitioned to an all-electronic refund system, absent a waiver permitting payment by paper check. For additional background on this transition, see <a href="https://www.thompsonhinesmartrade.com/2026/01/cbp-to-issue-all-refunds-electronically-starting-february-6-2026/">Update of January 6, 2026</a>.
<h2 class="wp-block-heading">2. Confirm Access to Your Account on ACE</h2>
Importers seeking timely receipt of IEEPA tariff refunds should also confirm they have established a profile&mdash;a &ldquo;Top Account&rdquo;&mdash;on the ACE.
Many importers assume that <a href="https://www.cbp.gov/sites/default/files/2025-12/cbp_form_5106.pdf" target="_blank" rel="noreferrer noopener">obtaining an importer of record (IOR) number</a> automatically creates a corresponding profile in the ACE. In practice, while CBP does register the IOR number in the ACE, importers do not automatically receive access to the trading data associated with that number. Instead, access is granted only after the importer submits a Top Account application to CBP linking the IOR number to the importer&rsquo;s ACE profile.
Establishing a Top Account in the ACE is a straightforward process and strongly recommended. It provides importers with direct access to their trade data at any time, reducing the need to rely on a customs broker to retrieve that information on the importer&rsquo;s behalf.
Need Assistance? If you need assistance establishing a Top Account in the ACE or have other questions related to securing IEEPA tariff refunds, please <a href="https://www.thompsonhinesmartrade.com/contact/">contact a member of our International Trade practice group</a>.

Two Steps Importers Should Take Now to Prepare for IEEPA Tariff Refunds

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