U.S. Customs and Border Protection (CBP) has provided new clarity on how importers can recover tariff payments — including certain duties previously thought unrecoverable — just as the Trump administration rolled out a fresh round of pharmaceutical tariffs and revised metals duties. Together, the developments signal continued volatility in trade policy and growing operational complexity for distributors navigating tariff exposure.

CBP Outlines Phased Tariff Refund System

In a March 31 court filing, CBP detailed its ongoing buildout of a new digital process to administer refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA), including — notably — a pathway to eventually process refunds on liquidated entries.

The system — called Consolidated Administration and Processing of Entries (CAPE) — is being developed within CBP’s Automated Commercial Environment (ACE) and will roll out in phases. It consists of four core functions:

• Claim Portal — 85% complete
• Mass Processing — 60% complete
• Review and Liquidation/Reliquidation — 80% complete
• Refund — 75% complete

Initially, Phase 1 of CAPE will focus on unliquidated entries and those within the 90-day reliquidation window. CBP estimates this will cover about 63% of eligible entries tied to IEEPA duties.

While the agency is not yet processing refunds on fully liquidated entries, it explicitly stated that future phases will include that capability — resolving a key uncertainty that had lingered for importers.

The filing also outlines how refunds will be executed. All payments are now required to be issued electronically, following a February 2026 rule tied to a broader federal push to digitize payments. As of late March, more than 26,000 importers — representing 78% of relevant entries and roughly $120 billion in duties — had enrolled to receive electronic refunds.

Looking ahead, CBP plans to expand CAPE functionality to handle more complex scenarios, including reconciliation entries, drawback claims, interest calculations and ultimately entries with final liquidation status.

What this Means for Distributors

For distributors, the biggest takeaway is optionality — and timing risk.

The confirmation that CBP intends to allow refunds on liquidated entries — even if not in Phase 1 — materially expands the pool of potentially recoverable duties. That raises the stakes for tracking historical tariff exposure and ensuring documentation is audit-ready.

At the same time, the phased rollout means recovery will be uneven. Distributors with unliquidated entries or those still within the 90-day window are best positioned for near-term refunds, while others may face a longer wait tied to future CAPE enhancements.

The shift to electronic refunds also introduces a practical requirement — distributors must ensure they are properly registered in CBP’s system or risk delays in receiving funds.

More broadly, the CAPE framework signals a more structured — but also more administratively intensive — approach to tariff recovery. Distributors should expect ongoing updates, evolving eligibility rules and potential compliance scrutiny as CBP builds out validation and enforcement tools.

White House Expands and Modifies Tariff Regime

Just one day after CBP’s filing, the Trump administration announced a new set of pharmaceutical tariffs while also modifying existing Section 232 tariffs on steel, aluminum and copper.

While details continue to emerge, the pharmaceutical tariffs represent a notable expansion of trade policy into a sector that has largely avoided broad-based duties in prior tariff cycles. Meanwhile, the metals tariff adjustments suggest a recalibration rather than a rollback — maintaining protectionist measures while refining their scope and application.

For distributors, particularly those in industrial, MRO and healthcare supply chains, the combined impact is twofold:

• Continued cost pressure tied to metals inputs and now potentially pharmaceutical-related goods
• Increased complexity in tariff classification, sourcing strategy and pricing pass-through

Bottom line

The juxtaposition of these developments underscores the current trade environment — one where opportunities to recover past tariff costs are expanding even as new tariffs are introduced.

For distributors, success will hinge on balancing both sides of that equation — aggressively pursuing refunds where available while staying nimble in response to new and evolving duties.