March 20, 2026

As of the morning of March 20, 2026, no additional public details have been released by U.S. CBP or the CIT following the March 19 reporting milestone. CBP is continuing to develop an automated, ACE based refund process, with further guidance expected. The information below reflects the most current understanding and is intended to help consumers monies prepare in advance of additional announcements. 

Preparing for Possible Tariff Refunds

Introducing the HIC Tariff Refund Tracker (TRT)

Recent developments involving tariffs imposed under the International Emergency Economic Powers Act (IEEPA) have raised the possibility that certain duties paid during the past year may become eligible for refund. Following recent court decisions, the U.S. Court of International Trade (CIT) has directed the government to establish a process for handling potential refunds.

U.S. Customs and Border Protection (CBP) is currently developing that administrative mechanism within its Automated Commercial Environment (ACE) system through a new refund processing portal referred to as CAPE (Consolidated Administration and Processing of Entries).

CBP has indicated that importers or their brokers will likely need to identify affected entries as part of the refund process, making advance organization particularly important.

While the final procedures are still being developed, importers are encouraged to begin organizing their customs entry records now. To assist companies in preparing for that possibility, the Hobby Industry Coalition (HIC) has developed the HIC Tariff Refund Tracker (TRT) — a practical tool designed to help importers organize key information associated with their import entries.

The TRT is structured to mirror how CBP processes entry data—at the entry, line, and payment levels—helping ensure consistency with potential ACE/CAPE refund workflows.

The tracker can serve two purposes:

Claim Preparation

If importers are required to submit refund requests, the TRT helps assemble the entry data needed to prepare those claims.

Refund Verification

If refunds are issued automatically through CBP’s administrative process, the TRT allows companies to confirm that eligible entries were included and that refund amounts correspond to duties originally paid.

The tracker organizes data at the tariff line level, allowing individual IEEPA duties (for example, 10% and 20% tariff lines) to be tracked and validated separately.

Most of the information needed for the TRT can be found in documents already maintained by importers and their customs brokers, including CBP Entry Summaries (Form 7501), which serve as the primary source of entry data. Broker reports and accounting records may be used to assist with data entry or validation. Importers may also benefit from maintaining access to supporting documentation, such as proof of duty payment, to assist with potential verification.

The following materials include a Quick Start Guide and a Tracker Template that companies may reproduce in their own spreadsheet systems. The objective is straightforward: to help importers organize entry information so they are prepared to either request or confirm tariff refunds if they become available.

While the Tariff Refund Tracker is designed to reflect how entry data is structured within CBP systems, the specific procedures for issuing IEEPA tariff refunds are still being developed. As a result, certain aspects of the process—including submission requirements and final implementation details—may change as CBP finalizes its approach. The TRT is intended to assist importers in preparing for this process based on currently available information.

Disclaimer

The information contained in this article is believed to be accurate as of the date of publication and is provided for informational purposes only. It should not be construed as legal, financial, or business advice. Readers should consult their customs broker, legal advisor, or other qualified professional and independently verify relevant information before making business decisions.

©️2026 Hobby Industry Coalition. All rights reserved.

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Hobby Industry Coalition (HIC)

Tariff Refund Tracker (TRT)

Section 1 — TRT Quick Start Guide

Recent developments involving tariffs imposed under the International Emergency Economic Powers Act (IEEPA) have raised the possibility that certain duties paid during the past year may become eligible for refund. While the administrative process for handling potential refunds is still being developed by U.S. Customs and Border Protection (CBP), importers can begin preparing by organizing the basic information associated with their affected import entries. 

What You Need Before Starting

Most of the information used in the TRT can be found in documents already maintained by importers or their customs brokers:

• CBP Entry Summary (Form 7501)

• Accounting, broker, or banking       records showing duty payments

Entry Summary Form Versions

During the period when tariffs were imposed beginning in March 2025, most entries were recorded using CBP Entry Summary (Form 7501) dated 5/22. Toward the end of this period, CBP introduced an updated version dated 02/26. A blank copy of CBP Entry Summary Form 7501-5/22 can be found at:

CBP Entry Summary Form

While the layout and numbering of certain blocks may vary slightly between versions, the underlying data fields remain consistent. For this reason, the TRT focuses primarily on the key entry data rather than specific block numbers.

Entry Data and CBP Systems

Information contained in the Entry Summary (Form 7501) is stored within CBP’s Automated Commercial Environment (ACE) system.

As CBP develops the CAPE (Consolidated Administration and Processing of Entries) portal to administer potential tariff refunds, ACE data is expected to form the basis for identifying eligible entries and calculating refunds.

Importers who wish to access their entry information directly through ACE may establish a “Top Account” within the ACE portal. Importers without ACE access may work with their customs brokers to obtain the necessary data.

Liquidation and Reliquidation

After duties are paid, CBP finalizes the duty calculation through a process known as liquidation. At liquidation, the duty owed on an entry becomes the final assessed amount. In certain circumstances—including when directed by court decisions—CBP may revisit entries through reliquidation, adjusting previously assessed duties.

As refund procedures develop, liquidation status and timing may affect how entries are processed, including whether refunds are issued automatically or require additional action. For this reason, tracking the Liquidation Date (if available) is recommended.

Using the Tracker Template

The TRT is designed to organize entry information in a way that aligns with how CBP calculates duties and is likely to process refunds. Before using the tracker, it is important to understand how Entry Summary data is structured.

Section 2 — Understanding Your Entry Data

How Shipments Are Structured (Important)

A single shipment (such as a container) may include multiple Entry Summaries (CBP Form 7501).

Each Entry Summary:

• is filed separately with CBP

• has its own Entry Number

• contains its own lines and       tariff calculations

• must be tracked independently

👉 Important: The TRT is organized by Entry Summary and line, not by container.

1. Entry Identification

• Entry No.

• Entry Date

• Liquidation Date (if available)

• Country of Origin

• Importer No.

• Importer of Record Name

• Port Code

2. Tariff Calculation Details

• Line No.

• HTSUS No.

• Entered Value ($)

• HTSUS Rate (%)

• Duty and IR Tax ($)

👉 Tariffs are calculated at the line level, not the entry level.

3. HTS Classification and IEEPA Tariff Programs

For each line item, the Entry Summary will typically show:

👉 One line item = multiple tariff layers

👉 Each must be recorded separately

4. Payment Tracking

• Entry No.

• Payment Method

• Amount Paid ($)

• Transaction Date

• Refund Received ($)

Section 3 — Building Your Tariff Refund Tracker 

Practical Note

The Tariff Refund Tracker (TRT) is most effective when maintained in a spreadsheet format. This allows entries to be easily sorted, updated, and reconciled as refund activity develops.

Because tariffs are calculated at the line level of the Entry Summary, users should record one row for each tariff line associated with an entry.

Suggested Spreadsheet Structure

Each row in the tracker should correspond to one tariff line reported on the Entry Summary (Form 7501).

How to Use This Structure

1. Work One Entry Summary at a Time

Select a single Entry Summary (Form 7501) and extract all relevant data before moving to the next entry.

👉 Do not organize data by shipment or container.

2. Record Each Line Separately

For each Line No. on the Entry Summary:

• Record the base HTSUS line       (e.g., 9503)

• Record each additional tariff       line (e.g., 9903 IEEPA lines)

👉 Each of these becomes a separate row in the tracker.

3. Capture All Required Fields

For each row, enter:

• Entry identification fields

• Line-level tariff data

• Duty amounts

Optional:

• Tariff Type (to distinguish       base vs. IEEPA lines)

4. Track Payments at the Entry Level

After all lines for an entry are recorded:

• Confirm total duties       paid

• Record payment method and       transaction date

5. Monitor Refund Activity

As refund procedures develop:

• Track refund amounts received

• Update entries as adjustments       or reliquidations occur

Notes

Payment information may be obtained from:

• ACH duty payments

• Customs broker statements

• Company accounting or banking       records

Tracking payment information helps confirm both the amount and timing of duties paid, which may be important when reconciling potential refunds and associated interest.

Administrative Note

Refund determinations will be administered by U.S. Customs and Border Protection (CBP) through procedures being developed within the Automated Commercial Environment (ACE) system.

In response to rulings by the U.S. Court of International Trade (CIT), CBP is developing a refund processing mechanism referred to as CAPE (Consolidated Administration and Processing of Entries).

These procedures may include adjustments to entry records and the liquidation or reliquidation of entries.

The TRT is intended solely to assist importers in organizing entry information so they can prepare for, or confirm, potential refunds.

Disclaimer

The Tariff Refund Tracker (TRT) is provided for informational purposes only. It does not constitute legal, customs, accounting, or financial advice, and does not determine eligibility for any refund. Importers should consult their customs broker, legal advisor, or other qualified professional regarding their specific circumstances. 

©️2026 Hobby Industry Coalition. All rights reserved.