U.S. Launches $166 Billion Tariff Refund via CAPE System – Mihan Logistics Reminder: Conduct Compliance Self-Assessment Before Claiming Refunds

Mihan Apr 07,2026

In April 2026, U.S. Customs and Border Protection (CBP) officially launched the CAPE electronic tariff refund system, involving a total refund amount of up to $166 billion (approximately RMB 1.13 trillion). This development stems from a U.S. Supreme Court ruling that the tariffs imposed by the Trump administration under the International Emergency Economic Powers Act (IEEPA) were unconstitutional. With toy manufacturer Learning Resources successfully recovering $11 million as a landmark, an unprecedented "tariff refund wave" has begun.

For international logistics providers and importers/exporters with a long-standing commitment to compliant operations, this presents a significant opportunity for capital repatriation. However, the simplified refund application process also signals a concurrent escalation in CBP's scrutiny of historical customs declaration data. Mihan Logistics reminds all clients: Refunds have eligibility criteria, and compliance is the prerequisite.

CAPE System: Automated Refunds with Full Data Transparency and Traceability

The CAPE system rolled out by CBP covers:

330,000 importers
53 million entry summary records

Refunds will include approximately 6% interest and be disbursed via electronic funds transfer. Processing time typically ranges from 45 to 90 days, with priority given to unliquidated entries or those within 80 days of liquidation. Over 1,000 companies, including FedEx and Costco, have already joined the refund application queue.

While this appears to be a "one-click refund" process, it is underpinned by CBP's comprehensive capabilities for full traceability of customs declaration data.

Logistics Perspective: Refund Applications May Trigger "Back Duties + Penalties"

Mihan Logistics alerts clients that U.S. Customs maintains a retroactive review period of up to six years for customs declarations, with particular focus on undervaluation, misdeclaration, and documentation inconsistencies.

In the following scenarios, we recommend suspending refund applications and prioritizing internal compliance reviews:

Shipments transported through comprehensive DDP dual-clearance channels with substantially underreported declared values
Declared values consistently maintained at 10–20% of marketplace selling prices
Inability to provide complete cost documentation, including purchase contracts, payment records, and freight allocation statements

CBP's Automated Commercial Environment (ACE) system now features intelligent cross-verification capabilities. It can extract selling prices from platforms such as Amazon and Walmart and automatically validate them against declared customs values. If a risk control alert is triggered, potential consequences include:

Payment of back duties + penalties of 2 to 4 times the underpaid amount
Placement on CBP's High-Risk Importer List, resulting in 100% inspection for all future shipments
Criminal liability for cases involving willful duty evasion exceeding $100,000

A Shenzhen-based enterprise was recently penalized for prolonged undervaluation declarations, with aggregate back duties and penalties exceeding $100,000. By contrast, the tariff savings it had initially gained amounted to merely $12,000, making the endeavor far more costly than beneficial.

Mihan Logistics Recommendations: Compliant Operations Ensure Safe Refund Claims

In response to this tariff refund window, we advise our clients to take the following steps:

Step 1 – Conduct Self-Assessment Before Applying

Review historical customs declaration data to ensure document consistency, reasonable valuation, and a complete cost chain. If uncertainties arise, engage professional logistics or customs advisory services for assistance with compliance reviews.

Step 2 – Avoid Reckless Action If Non-Compliant

If past customs clearance records contain obvious irregularities, do not rush to file refund applications via the CAPE system. In such cases, "pausing" is wiser than "taking risks."

Step 3 – Compliant Enterprises Should Proactively Claim Refunds

For clients who have consistently adhered to compliant declaration practices, Mihan Logistics can assist in organizing customs documentation to support the legal and efficient recovery of entitled tariff refunds through the CAPE system.

Final Note

The 2026 tariff controversy is both an opportunity and a warning. The law protects those who operate within regulatory frameworks. In the era of big data enforcement, there is no room for chance or shortcuts.

Mihan Logistics remains committed to providing professional, compliant, and efficient international logistics services. Regardless of how tariff policies evolve, compliance remains the strongest defensive moat for businesses.

Should you have any questions regarding the tariff refund process or require assistance with customs data audits, please do not hesitate to contact the Mihan Logistics Customs Compliance Team.

Mihan Logistics – Moving every shipment with greater steadiness and farther reach.

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