Today (April 20) marked the first day businesses could file for refunds on tariffs invoked by President Donald Trump under the International Emergency Economic Powers Act (IEEPA), with law firm Fox Rothschild offering key guidance for dealers.
First things first: The refunds, stemming from a U.S. Supreme Court ruling in February that found the tariffs unconstitutional, are expected to total $166 billion across more than 330,000 importers and over 53 million shipments.
U.S. Customs and Border Protection will distribute refunds through a new federal process, the Consolidated Administration and Processing of Entries (CAPE) program.
Eligible businesses will receive a single electronic payment (plus interest, if applicable) instead of entry-by-entry refunds, according to Reuters.
CBP says most valid claims will be paid within 60–90 days of approval, though more complex cases may take longer.
What they’re saying: “CAPE Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation,” noted U.S. Customs and Border Protection in a press statement.
Why it matters: For dealers and dealer groups, the refunds could represent a meaningful opportunity to recover costs tied to imported vehicles or parts. But accessing that money will depend on having the right documentation and understanding how eligibility applies to past transactions.
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Between the lines: Fox Rothschild’s Automotive Practice Group outlined several key considerations for dealers that may be eligible for refunds.
Documentation is critical, as eligibility depends on accurate entry data, including importer-of-record information, tariff classifications, and payment records.
Coordination may be required, as the party that paid the tariff may differ from the one that ultimately absorbed the cost.
Refund rights could affect ongoing transactions, including buy/sell activity, valuations, and post-closing adjustments.
The scope of qualifying entries may include certain unliquidated or recently liquidated imports, entries where tariffs were assessed under the affected authority, and claims supported by accurate documentation and classification data, per Fox Rothschild.
Bottom line: The refund process could unlock significant dollars for some dealers, but it is not automatic. Those who move quickly, verify their documentation, and understand their eligibility will be best positioned to capture any opportunities tied to the refunds.
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