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CBP Gives Update on IEEPA Refunds


Customs and Border Protection filed its latest status update  to the Court of International Trade last week, which indicates that its new electronic refund system is still on track to come online later this month.

Phase 1: In its update, CBP explained that the new Consolidated Administration and Processing of Entries system will start by accepting refund claims for unliquidated entries and liquidated entries falling within the voluntary 90-day reliquidation period.

  • CBP estimates this covers approximately 63% of entries for which International Emergency Economic Powers Act duties were paid or deposited.
  • Certain other entries will also fall under this phase, but only after liquidation: entries for which the liquidation status is “suspended,” “extended” or “under review” and warehouse and warehouse withdrawal entries.

The timeline: CBP pledges to process refunds within 45 days from the date of the acceptance of the request—unless there is a “compliance concern,” which requires further review.

Phase 2: In the second phase of its rollout, which has not yet been scheduled, the system will address liquidated entries outside of that period, including those that have reached final liquidation.

Keep an eye out: CBP’s next progress report is due April 14.

Learn more: To learn more about the coming system and what manufacturers should know about the refund process, join the NAM’s international policy team and legal team for a webinar this Thursday, April 9, at 4:00 p.m. EDT.

  • This exclusive event for NAM members will feature experts Michael Jacobson of Hogan Lovells’ trade litigation practice and Katie Wellington of Hogan Lovells’ appellate and Supreme Court litigation practice.
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