In a declaration submitted to the United States Court of International Trade, a senior official from U.S. Customs and Border Protection (CBP) outlined major operational and technological constraints affecting implementation of the court’s order requiring the removal and refund of tariffs imposed under the International Emergency Economic Powers Act (IEEPA).
The declaration was filed in Atmos Filtration, Inc. v. United States in response to the court’s March 2026 order directing CBP to liquidate unliquidated entries without applying IEEPA duties and to reliquidate certain entries where liquidation has not yet become final. According to CBP, the scale of affected import transactions is unprecedented. As of 4 March 2026, more than 330,000 importers had filed over 53 million import entries involving IEEPA duties, representing approximately USD 166 billion in tariff collections, with around 20.1 million entries still unliquidated.
CBP explained that its Automated Commercial Environment (ACE), the agency’s primary import processing system, was not designed to immediately reverse tariff collections of this magnitude. Duty deposits are often combined within entry summary lines, which makes it difficult to isolate the precise portion attributable to IEEPA tariffs. As a result, CBP personnel would need to manually recalculate duties for many entries before refunds could be processed.
The agency estimates that processing refunds under existing procedures would require approximately 4.4 million staff hours, since each entry would need to be individually amended, recalculated, and certified before payment is issued.
To address these challenges, CBP is developing new functionality within ACE that would allow importers to submit refund declarations and enable the system to automatically recalculate duties and aggregate refunds by importer. CBP estimates the new process could reduce the required workload by more than four million hours and aims to deploy the system within approximately 45 days.
Please read the following court document as submitted by CBP:
https://storage.courtlistener.com/recap/gov.uscourts.cit.19346/gov.uscourts.cit.19346.31.0_1.pdf