U.S. Customs and Border Protection is set to launch a claims portal Monday to process tariff refunds tied to recent court rulings, with potential repayments totaling an estimated $166 billion.
Finance leaders are expected to play a central role in steering their organizations through the process, with success hinging on documentation quality, cross-functional coordination and how companies account for any eventual refunds.
The effort is reminiscent of pandemic-era relief programs such as the Paycheck Protection Program and Employee Retention Credit, where CFOs served as the final checkpoint for compliance, accuracy and financial reporting, according to Bryan Graiff, who leads manufacturing and distribution for accounting and consulting firm Armanino.
“While other teams may gather the data, the CFO is ultimately responsible for ensuring its accuracy and determining the proper accounting treatment,” Graiff said in an interview.
The U.S. Court of International Trade issued a ruling last month finding that tariffs struck down by the U.S. Supreme Court in February must be refunded. Graiff said there is still a sense of unease in the trade community over the possibility of an eventual appeal by the administration.
Despite that uncertainty, Graiff said companies should not wait for final clarity before acting.
“We’re advising our clients to prepare for the opportunity to get a refund, because we think it’s going to be a pretty complex process, and there’s going to be a lot of work to do to prepare for that,” he said.
Recent efforts at CBP have given companies strong reason to hope that a viable refund process is taking shape, according to Nghi Huynh, partner-in-charge of transfer pricing at Armanino.
“There is definitely positive momentum,” she said, pointing to CBP’s plan to launch its portal Monday, though she cautioned there could be “some slippage on that date.”
CBP is expected to introduce a phased rollout, with the agency estimating that roughly 63% of refunds will be handled in the initial stage.
As of April 9, about 56,497 importers had completed steps to receive electronic refunds, representing roughly $127 billion in duties, CBP said Tuesday in a filing before the Court of International Trade.
“What changes on Monday is the launch of the claims portal itself,” Huynh said. “That’s when importers can begin formally submitting their refund claims and supporting documentation, which will allow CBP to start reviewing and processing those requests.”
In its Tuesday filing, CBP provided an update on its Consolidated Administration and Processing of Entries program for processing refund claims, saying the agency has completed “the primary development of all components and functionalities for CAPE Phase 1.”
“The agency has transitioned to an intensive testing posture, focused on performance and scenario-based testing of all CAPE components and the remediation of any defects identified during testing,” CBP official Brandon Lord wrote in the filing.
Documentation — including detailed records of tariff payments, shipment contents, inventory positions, and product-level flows — will be critical in navigating the CBP process, according to Graiff.
He warned that complexity compounds quickly at the stock-keeping-unit level: “One container could have thousands of SKUs involved.”
Companies that have handled tariffs inconsistently — when it comes to passing on versus absorbing costs, for example — could be in store for a challenging claims process, Graiff said. But even those that believe they absorbed 100% of the costs may still need to demonstrate how pricing decisions were made over time. “It can just get unwieldy very quickly,” he said.
Besides ensuring proper documentation, CFOs should also prepare by assessing potential “downstream impacts” of receiving a refund, such as financial reporting and tax-related issues, according to Huynh.
“For some companies, this could be a very sizable dollar amount,” she said.
Graiff said close CFO coordination with other teams will be critical, especially supply chain and procurement leaders who are closest to the underlying transactions and supplier relationships.
“They’ll be key in pulling together the necessary documentation, with the CFO helping ensure all inputs are aligned, accurate, and ready for submission,” he said.
