CBP To Require Electronic Refunds Through the ACE Portal
U.S. Customs and Border Protection (CBP) has finalized a new rule requiring that all CBP refunds be issued electronically via automated clearing house (ACH) through the Automated Commercial Environment (ACE) portal, eliminating paper refund checks. This applies to all types of refunds, including duty drawback and potential refunds that may come if IEEPA is overturned. This makes it crucial for all importers to gain access to their ACE portal accounts and to opt in to electronic refunds. If an importer already uses ACH for duty payments, they must still opt in for refunds.
Effective Date: Feb. 6, 2026
What this means for importers:
- All duty, tax, and fee refunds issued by CBP will be paid via ACH to a U.S. bank account.
- Importers must have an active ACE portal account and enroll in the ACH refund program.
- Importers without a U.S. bank account may designate a customs broker with a U.S. bank account to receive refunds on their behalf. This must be done within the importer’s ACE account.
Action recommended:
- Verify that your CBP Form 5106 information is current, particularly for points of contact. When your company applies for an ACE account, a verification email will be sent to the email address that is listed on the 5106.
- If your company has not yet applied for an ACE account, apply for an ACE Account online at CBP’s ACE portal.
- Confirm that your ACE Portal access is active.
- Ensure your ACH refund authorization is completed and approved.
Failure to enroll may result in delays in receiving refunds once paper checks are discontinued.
For importers and other parties who may receive CBP-issued refunds after Feb. 5, 2026, review CBP’s electronic refund enrollment reference sheet and take any necessary steps to ensure readiness for this mandatory transition.
CPSC Certificate E-filing Webinar
Beginning July 8, 2026, importers of consumer products regulated by the U.S. Consumer Product Safety Commission (CPSC) will be required to electronically file Children’s Product Certificates and General Certifications of Conformity.
Section 232 Lumber Tariffs: No Increase in 2026
The White House has issued an amendment delaying the previously announced increase in Section 232 tariffs on certain timber, lumber and derivative wood products.
Key update:
- The existing Section 232 tariff rates remain in effect through all of 2026.
- The planned tariff increase originally scheduled for Jan. 1, 2026, has been postponed to Jan. 1, 2027.
What this means for importers:
- Current Section 232 duty rates on applicable lumber, wood furniture, cabinets and related products remain unchanged for 2026.
It is recommended to continue monitoring sourcing strategies and tariff exposure ahead of the 2027 effective date.
ISPM 15 Requirements for Wood Packaging Material (WPM)
The U.S. Department of Agriculture’s (USDA’s) Animal and Plant Health Inspection Service (APHIS) has confirmed that the temporary enforcement pause related to the missing hyphen in ISPM 15 markings ended Dec. 31, 2025.
What changed for Jan. 1, 2026:
- CBP and APHIS will once again enforce the requirement for a hyphen between the two-letter country code and the producer code, as required under ISPM 15 Annex 2.
- All other ISPM 15 requirements have remained in effect and continue to be enforced.
Shipments containing noncompliant WPM may be refused entry, delayed or subject to rework or export.
Action recommended:
- Importers should confirm that suppliers and WPM manufacturers are using fully compliant ISPM 15 marks, including the required hyphen.
New Section 301 Tariffs on Nicaragua, DR-CAFTA Originating Goods Exempt
The Office of the U.S. Trade Representative has implemented a new Section 301 action targeting Nicaragua due to labor rights and rule-of-law concerns.
Key points:
- Additional Section 301 duties apply to goods of Nicaraguan origin that do not qualify as originating under the Dominican Republic-Central America Free Trade Agreement (DR-CAFTA).
- DR-CAFTA originating goods remain exempt from these additional tariffs.
Phased tariff schedule for goods that do not originate under DR-CAFTA:
- Jan. 1, 2026, 0% additional duty
- Jan. 1, 2027, 10% additional duty
- Jan. 1, 2028, 15% additional duty
Compliance considerations:
- Accurate country-of-origin determinations are critical.
- DR-CAFTA qualification and Certificate of Origin should be reviewed and documented prior to shipment. Certificates of Origin must be available at the time of entry.
- These Section 301 duties may stack with most-favored-nation (MFN) duties and other applicable trade remedies.
