The Tariff Reset Is Here: Refunds Begin While New Duties Take Their Place
The United States has entered a new phase in trade policy where tariff relief and new tariff exposure are happening at the same time. Recent actions from federal agencies confirm a shift in both how duties are applied and how they may be recovered.
The End of IEEPA Duties and What It Means
The White House formally ended the collection of certain tariffs imposed under the International Emergency Economic Powers Act. Federal agencies were directed to stop collecting these duties and begin implementing the change across systems.
This action does not eliminate all tariffs. It specifically removes IEEPA-based duties while leaving other tariff authorities fully intact.
A New Global Tariff Has Replaced Them
At the same time, the White House introduced a new tariff framework under Section 122 of the Trade Act of 1974.
A 10 percent ad valorem duty now applies to most imports
The measure is temporary, limited to up to 150 days unless extended
The goal is to address balance of payments concerns and domestic production
This new duty operates alongside existing tariffs and is treated as a standard customs duty.
Important Structural Detail: Tariffs Are Stacking Differently
The Section 122 tariff:
Applies broadly across imports
Does not stack on top of Section 232 tariffs where those already apply
Still applies to portions of goods not covered by other tariff programs
This creates a more layered tariff environment rather than a single unified rate.
Refunds Are Now Moving Into a Structured System
At the same time, CBP has introduced a new system to handle potential refunds tied to prior IEEPA duties.
Through CSMS #68315804, CBP confirmed:
Launch of the CAPE system on April 20, 2026
Creation of an electronic pathway for refund claims
A shift away from entry by entry processing to consolidated refund handling
Phase 1 of CAPE will focus on:
Certain unliquidated entries
Entries within a defined post liquidation window
Future phases will expand to more complex scenarios.
CAPE Changes How Refunds Will Be Handled
Under CAPE:
Importers or brokers submit claims through the ACE Portal
CBP removes IEEPA tariff lines and recalculates duties
Entries are reviewed and liquidated or reliquidated
Refunds are issued in a consolidated format rather than per entry
Critical Clarification on Refunds
CAPE does not create refunds on its own.
Refund eligibility remains dependent on:
Legal authority such as court decisions
Entry status including whether entries are liquidated
CBP review and proper filing procedures
This distinction is key.