The recovery of tariffs is under way, as U.S. Customs and Border Protection (CBP) activates its refund portal.
What was previously a legal ruling is now a large-scale operational programme, with businesses beginning to submit claims and recover duties paid.
The scale is significant. Around 330,000 importers are estimated to have paid approximately $166 billion in tariffs, with tens of millions of individual entries now subject to review. Early engagement is already high, as thousands of businesses move to secure reimbursement.
However, this is not a simple refund exercise. It is a complex, data-driven reconciliation process where success depends on accuracy, documentation and the ability to navigate CBP’s validation requirements.
A phased process with defined timelines
CBP has implemented a phased rollout to manage volume. The initial stage focuses on unliquidated entries and those within 80 days of liquidation, covering more than 60% of affected transactions.
Once submitted, claims are processed through automated batch systems and assessed against historical entry data. Where validated, reimbursement is expected within 60 to 90 days of approval. However, these timelines are conditional and may extend as volumes increase and more complex claims enter the system.
Given the scale of the programme, delays are likely. Tens of millions of entries must be verified, and each claim is subject to compliance checks before approval.
Why recovery is not automatic
Every claim must be matched against original customs declarations. This includes validating tariff classifications, confirming importer-of-record status and checking whether entries have already been liquidated or adjusted.
Additional controls are in place to prevent duplication or overlap with previous disputes or amendments. Any inconsistency between submitted data and CBP records is likely to trigger delays or rejection.
For exporters operating under Delivered Duty Paid (DDP) terms, the requirements are stricter. Where the exporter acted as importer of record, they must demonstrate full ownership of the customs process and provide supporting documentation to substantiate the claim.
At this scale, even small data errors can have a material impact, particularly where large volumes of entries are involved.
What importers need to do now
With the submission window open, preparation is critical. Importers should prioritise:
- Identifying all affected shipments and entry summaries across the relevant period
- Confirming importer-of-record status for each transaction
- Verifying tariff classifications used at the time of entry
- Reviewing liquidation status, including entries within the 80-day window
- Checking for prior amendments, disputes or duty adjustments
- Consolidating supporting documentation, including commercial invoices and entry records
- Structuring data in a format aligned to CBP submission requirements
Taking these steps early will reduce the risk of delays, improve validation outcomes and accelerate reimbursement.
Turning eligibility into recovery
While the financial opportunity is substantial, recovery depends on execution. Businesses must translate historical exposure into compliant, well-documented claims that can pass CBP scrutiny.
This is particularly challenging for organisations with high shipment volumes, multiple importer-of-record structures or complex trade flows.
Global Forwarding provides end-to-end support to manage both the technical and administrative complexity of tariff refund claims. Our customs specialists work across U.S. and global operations to:
- Analyse historical shipment and entry data to identify eligible claims
- Validate tariff classifications and ensure alignment with CBP records
- Confirm importer-of-record status across all transactions
- Prepare and submit claims through the ACE platform
- Manage communication with CBP and respond to queries or discrepancies
- Track claim progress and provide visibility through to reimbursement
With experience handling high-volume customs data and complex entry structures, Global ensures claims are accurate, complete and positioned for efficient processing.
If your business has imported into the United States or operated under DDP terms, now is the time to assess your exposure and begin preparing claims.
Global Forwarding can support you at every stage, helping convert potential entitlement into confirmed financial recovery with accuracy, control and confidence.
