Effective Friday, Feb. 6, 2026, U.S. Customs and Border Protection (CBP) will issue all refunds electronically via automated clearing house (ACH), subject to limited exceptions. This requirement was announced in CBP’s electronic refunds interim final rule, published in the Federal Register on Jan. 2, 2026.
Under this rule, paper refund checks issued by the U.S. Treasury will be eliminated. All trade participants who may receive CBP refunds, including duty refunds, post-summary corrections, protests, and drawback, must be enrolled to receive refunds electronically.
What Importers Need To Know
- Automated Commercial Environment (ACE) portal access is required. Importers must have an active ACE portal account.
- ACH banking information must be submitted in ACE. Banking details must be entered in the ACH “Refund Authorization” section of the ACE Portal. CBP has confirmed that ACH refund enrollment is required even if you already use ACH debit or a periodic monthly statement (PMS) for duty payments.
- U.S. bank account required.
- Importers with a U.S. bank account may enroll directly.
- Importers without a U.S. bank account must either open one or designate a U.S. customs broker with a U.S. bank account, consistent with 31 U.S.C. § 3332(g), using CBP Form 4811.
- Once ACH refund enrollment is approved, all future CBP refunds will be issued electronically to the designated U.S. bank account.
Consequences of Not Enrolling
- If CBP certifies a refund but cannot issue it electronically due to missing or incomplete ACH information, the refund will be rejected.
- No interest will accrue on rejected refunds under 19 U.S.C. § 1505(d).
- To reissue a rejected refund, the importer must:
- Complete the ACH refund application in ACE.
- Notify CBP’s refunds team at frn-achrefundsupport@cbp.dhs.gov to request reissuance.
How To Get Started
- Update CBP Form 5106.
- Ensure all required fields, including the contact email address, are accurate. CBP will send an email verification to the address listed on the CBP Form 5106 once an ACE application is submitted.
- Open or access your ACE portal account.
- After confirming the 5106 is on file with the correct email, apply for an ACE portal importer account.
- Enroll in ACH refunds.
- Log in to ACE.
- Select your importer subaccount.
- Navigate to “ACH Refund Authorization.”
- Click “Get Info/Refresh,” enter your banking routing and account numbers, then click “Update.”
CPSC E-Filing Guidance and High-Risk HTS Code List
The U.S. Consumer Product Safety Commission (CPSC) has issued updated guidance to assist importers with compliance under the electronic filing (e-filing) requirement for certificates of compliance. There is a list of approximately 600 Harmonized Tariff Schedule (HTS) codes that CPSC has identified as likely to include products subject to mandatory safety standards or otherwise considered high-risk. This list is intended as a compliance aid and does not represent a complete universe of HTS codes for which an electronic certificate may be required.
Importers remain fully responsible for ensuring that a certificate is e-filed whenever required, regardless of whether the HTS code appears on the list. The list is designed to help the trade community understand when CPSC and CBP are more likely to coordinate and flag specific HTS codes, as well as when filing a voluntary disclaimer message may be appropriate. In certain circumstances, a voluntary disclaimer may positively impact an importer’s risk profile within CPSC’s targeting system.
CPSC also reminds the trade community that any entry with an e-filed certificate submitted through the CPSC partner government agency (PGA) message set will be subject to the CPSC 1USG messaging process. In addition, some products that do not require certification may still be routed through 1USG messaging. Importers are encouraged to review CPSC’s 1USG messaging guidance to understand which product categories are impacted and how messaging requirements may affect clearance timelines.
What This Means for You
- Review your HTS classifications carefully. If your products fall within the HTS codes listed in the attached guidance, additional scrutiny by CPSC and CBP is more likely.
- Be prepared to e-file certificates when required. The obligation to e-file rests with the importer, even if the HTS code does not appear on the CPSC list. Effective July 8, 2026, any product that is subject to a Consumer Product Safety Commission rule, ban, standard or regulation must be covered by an individual electronically filed CPSC certificate.
- Understand when disclaim messages may be appropriate. For products not subject to CPSC certification, a voluntary disclaimer message may help reduce targeting risk when filed correctly.
- Plan for 1USG messaging impacts. Entries with e-filed certificates and certain noncertifiable products will move through the 1USG messaging process, which can affect release timing.
- Coordinate early with your broker. Proactive review of product scope, certification requirements, and messaging strategy before shipment can help avoid delays, holds or enforcement issues.
Preparing for Tariff Shifts: Know When Duty Rates Are Set
Duty rates are set by two key factors: the arrival date and the U.S. Customs and Border Protection release date. Duties do not become applicable until the vessel has arrived at the port, typically meaning anchored or docked within the port limits of U.S. customs territory for vessel shipments. Additionally, once customs releases the shipment (often called “entry”), the applicable duty rates are fixed based on that release date. While cargo may be released by customs after arrival, importers should be mindful that demurrage can accrue if a container remains at the terminal while awaiting customs release.
Importers should also note that merchandise must be formally entered within 15 calendar days of arrival at the port. Shipments not entered within this timeframe are subject to general order procedures.
Time of Entry Under 19 CFR § 141.68
Under 19 CFR § 141.68, the “time of entry,” which determines the applicable duty rate, is established as follows when entry documentation is filed.
When the entry documentation is filed in proper form without an entry summary, the “time of entry” will be:
- The time the appropriate CBP officer authorizes the release of the merchandise or any part of the merchandise covered by the entry documentation
- The time the entry documentation is filed, if the merchandise has already arrived within the port limits
- The time the merchandise arrives within the port limits, if the entry documentation is submitted before arrival
When an entry summary serves as both the entry documentation and entry summary, in accordance with § 142.3(b) of this chapter, the time of entry will be the time the entry summary is filed in proper form with estimated duties attached.
Other conditions, such as merchandise under immediate delivery procedure, quota-class merchandise or withdrawal from warehouse for consumption, may be viewed at this link.
Determining the Appropriate Customs Release Timing
When determining the optimal timing to enter and release merchandise while awaiting potential IEEPA tariff trade deals, importers should carefully weigh the potential duty savings against the risk of accumulating detention and demurrage costs. In some cases, as seen with the Switzerland-United States trade agreement, implementation dates have been applied retroactively, and post-summary corrections were permitted to request refunds on previously filed entries. However, this outcome is not guaranteed, as each trade agreement and tariff action is implemented differently.
