US tariffs: How to get refunds, key dates and what comes next

For businesses importing goods into the US, recent developments have opened the door to mitigating some of the impacts of previous efforts, alongside new challenges. Following the US Supreme Court’s decision to strike down recent tariffs , US Customs and Border Protection (CBP) has launched a portal to process billions of dollars in refunds. Alongside this, new “full value” assessments for Section 232 tariffs and proposed valuation reforms are changing how import duties are calculated. 

The complexity of the measures will require UK exporters to coordinate with US partners to secure eligible refunds and adjust pricing strategies to account for these updated calculations. Michael Starr, VP US at Zencargo special guest David Murphy Esq, Partner at international trade and customs law firm, GDLSK discussed the changes on our recent webinar, Tariff Talk: Refund timelines and the 2026 trade roadmap. 

Click here to watch the recording or catch up on the latest news below. 

What you need to know about the the IEEPA Refund Process

A significant amount of capital is eligible for refunds. According to CBP court filings, over 330,000 importers paid an estimated $166 billion in these now-nullified duties.

As of April 20th, CBP launched the portal designed to process these reimbursements. Known as CAPE (Consolidated Administration and Processing of Entries), the portal is accessed through the Automated Commercial Environment (ACE) system.

Phase 1 eligibility & technical requirements 

The government is processing refunds in phases, focusing initially on recent tariff payments. Phase 1 is limited to unliquidated entries and those within 80 days of liquidation. 

• Entries beyond the 90-day reliquidation window are currently excluded from this automated processing phase. CBP has deferred Reconciliation entries (Type 09), Drawback claims, and entries with Open Protests to subsequent phases.
• Importers or their authorised customs brokers must submit a “CAPE declaration”. This requires uploading a CSV file containing up to 9,999 entry numbers to trigger the removal of the duties. 
• Accuracy will be a key concern; if formatting or data is incorrect, or if an unqualified entry is included, CBP may reject the line item or the entire batch.

Steps for UK shippers 

UK exporters should coordinate with their US buyer partners and Importers of Record (IORs). CAPE will consolidate these refunds, including interest, by IOR and liquidation date.

• To receive funds, importers must register for CBP’s electronic payment system and submit their bank account information. 
• As of mid-April, only about 56,500 of the eligible importers had completed this enrollment. CBP states it generally aims to issue refunds within 60 to 90 days of accepting a valid declaration , though officials have noted the broader refund process could take longer to fully resolve.

For B2C shippers, retail customers may see these refunds passed down through delivery companies. For example, FedEx has stated it will return tariff refunds to customers once received from CBP, and planned to begin filing claims on April 20th.

Section 232 changes: New full value assessments

Regulatory changes are also affecting how current tariffs are applied. An update to Section 232 tariffs took effect on April 6th 2026.

Previously, these tariffs focused on the metal content within imported goods. Now, Section 232 tariffs are assessed on the full customs value of the imported product.

The 15% rule for products classified outside of the standard metal chapters (HTSUS 72-76), a 15% weight threshold now applies. If less than 15% of the total weight of the imported article is made of metal, the product is not subject to the Section 232 duty.

For UK manufacturers exporting multi-component goods, this changes landed cost calculations. A product that contains minimal metal but carries high fabrication costs now faces a tariff on its total price. Previously, the importer only paid duty on the fraction of the value attributed to the metal.

The administration has also ended the formal “inclusions process,” allowing the Secretary of Commerce and the USTR to add new derivative articles to this “full value” regime on a rolling basis.

Proposed Valuation Reform: First Sale vs. Last Sale

The April 6th pivot toward “full value” assessments is viewed as a testing ground for broader valuation reform. A primary consideration for transatlantic supply chains is the proposed elimination of the “First Sale” rule.

Understanding First Sale vs. Last Sale 

US valuation law generally bases the value of imported goods on the sale for export to the United States. However, the 1992 “First Sale” principle provides an option for multi-tier supply chains.

If a US importer buys from a UK middleman, who contracts a manufacturer, the First Sale rule allows the duty to be calculated based on the earlier, lower factory price, rather than the middleman’s markup.

Proposed legislation introduced in February 2026, the Last Sale Valuation Act (LSVA), seeks to mandate “Last Sale” as the only basis for duty. If enacted, it would eliminate the First Sale principle.

Importers using intermediary markups would see their dutiable values rise to the final price paid by the US buyer. For example, if a factory price is $80 and the UK middleman sells it to the US importer for $100, the current rule assesses duty on the $80. Under the proposed rule, the duty would be assessed on the $100, resulting in a 25% valuation increase.

The 2026 trade roadmap: Key dates

The administration’s trade strategy includes several upcoming milestones:

• Late April: On April 28th, the Court of International Trade (CIT) will hold a progress report and settlement conference. This will provide updates on how the CAPE portal is functioning.
• Early May: Section 301 hearings will take place from May 5th to 8th. These cover two investigations, including one into 16 partner nations regarding “structural excess capacity” disrupting US trade.
• Late July: On July 24th, the existing Section 122 tariffs are set to expire, unless extended by Congress. On July 31st, a 100% tariff is scheduled to go into effect for 17 pharmaceutical companies and targeted semiconductor imports.

What to do now

For shippers in the US and UK, the changes in the tariff sector are far from over. For now, the key focuses should be:

• Auditing your customs records: Review your data in the US customs system (ACE) to ensure all your import classifications and records are perfectly accurate before submitting any refund claims.
• Set up your refund accounts: Ensure your US partners have their bank details registered and configured in the new CAPE portal. If this isn’t set up correctly, your electronic tariff refunds will be delayed.
• Review your pricing: With new “full value” assessments changing how US import taxes are calculated, you need to review your pricing models immediately to ensure your profit margins aren’t wiped out by surprise duty fees.

Need help navigating these changes? Our customs team at Zencargo are ready to advise you on the best way to structure your imports for maximum tariff efficiency and help you manage your costs . We can also help you audit your supply chain, plan for your eligible refunds, and adapt your strategy for what’s next in 2026. 

Get in touch today.