By the Frost Law Editorial Team
It’s a historic time for IEEPA tariff refunds following a Supreme Court ruling, but importers are struggling with basic issues that complicate getting their money. To help importers navigate this unusual situation, Frost Law is providing a special four-part series focused on the ACE system — the Automated Commercial Environment — an overlooked but critical step to generate tariff refunds.
It’s a common problem being seen for importers trying to claim an IEEPA tariff refund.
The first step is registering through the U.S. Customs and Border Protection’s ACE portal – the Automated Commercial Environment. But when you tried to register for ACE to get your tariff refund moving, you hit a wall right away because an account already exists tied to your Employer Identification Number (EIN).
You didn't set it up. Nobody currently at your company did either. And the ACE system has no capability in telling you who did.
Here's the part that's genuinely frustrating: Right now, someone other than you has control over your company's import account with the U.S. Customs and Border Protection (CBP). Until that gets resolved, there's no filing the refund.
If that's exactly where you are, call Frost Law at (410) 497-5947, and our team will get to work with CBP on identifying the account holder.
Ever since the Supreme Court's February 20, 2026 ruling in Learning Resources v. United States made IEEPA tariffs refundable, CBP has been running the CAPE process to get that money back to importers.
Those refunds go through the ACE portal as a CAPE Declaration, with payment made by an ACH transfer posted inside that same system, under the Electronic Refunds Interim Final Rule that took effect January 2, 2026. No access to the system means no filing, and no filing means no refund. The full chain is laid out in Frost Law’s special guide to ACE access problems.
Time and again, Frost Law finds the ACE account problems trace back to one of the same three sources:
Whoever it was is now your firm’s Trade Account Owner, or TAO, the person ACE considers the sole controller of that account.
That role doesn't sunset. It doesn't reset when an employee leaves or a broker relationship ends. It just stays locked to your EIN until someone formally changes it, which explains why a fresh registration is off the table. CBP's guidance specifically tells applicants to check for an existing top account first because the system rejects duplicate numbers tied to one identifier.
In the ACE system, no button exists to simply reclaim an account.
But there is a single self-service step worth knowing about, along with its real limits. Emailing ACE.Support@cbp.dhs.gov with "Trade Account Owner Lookup" in the subject line prompts CBP to contact whoever's on file as the TAO, and they'll let you know the outreach was sent.
That's as far as it goes. CBP contacts the owner directly, they won't tell you who that owner actually is. If that person is long gone from the company, or tied to a broker relationship you ended years ago, the message likely just disappears into an unread inbox, leaving you no further along than before, only with less time to spare.
CBP has automated a few pieces of account management recently, including, TAO reactivation that lets an active TAO manage other users on the account independently. None of that helps, though, when the TAO itself is the obstacle because you can't operate controls on an account that isn't yours to control.
What's actually required is a records-based process with CBP that pinpoints who currently holds the account, documents your company's rightful claim, and pushes CBP to reassign or rework the ownership. Every one of those is a formal request that needs the correct paperwork attached, and needs someone chasing it down afterward.
That chasing is usually where things break down. Requests go unanswered. Documentation gets requested once, then requested again. Because CBP alone can execute the actual change, the real skill is in knowing what to ask for and refusing to let the request go cold.
A stale Form 5106, the identity record CBP keeps on your company, can sink this same fix if it's also out of date. Frost Law covers that specific pitfall in our guide to updating Form 5106.
This is precisely the kind of problem-solving Frost Law does for refund clients as a matter of course. Find out if your imports qualify for an IEEPA refund, and we'll take the account-ownership issue on with CBP directly.
Here’s another common pitfall: A closely related error appears when adding an importer sub-account, a duplicate EIN or duplicate tax identification message.
It's the same underlying issue in different clothing. Your EIN already exists somewhere in CBP's records. Sometimes it’s filed under a different suffix, and sometimes it’s attached to a name your company doesn't recognize. That's your cue that you're facing a records problem, not a typo.
The fix mirrors the unknown-account situation exactly: You need to determine what CBP actually has on file, then get it corrected.
Any year, an unclaimed account on your EIN would be worth resolving. This year, for importers seeking a refund, it's actively costing you money.
The deadlines involved don't slow down while you're tracking down a broker relationship from years ago. Once an entry liquidates or reliquidates, an 180-day window opens to file a protest.
If your entries have already finally liquidated, and a case at the Court of International Trade becomes necessary, two key dates matter:
Do nothing, and here's the result: The account stays under someone else's name, your window for filing keeps shrinking, and a refund your company has earned remains locked behind a login you can't use.
Use the form below to tell Frost Law the error you're running into, and we'll give you a straight answer on who's most likely holding your account and what it'll take to get it back. And you can also call us at (410) 497-5947 with other tariff questions.
By the Frost Law Editorial Team
It’s a historic time for IEEPA tariff refunds following a Supreme Court ruling, but importers are struggling with basic issues that complicate getting their money. To help importers navigate this unusual situation, Frost Law is providing a special four-part series focused on the ACE system — the Automated Commercial Environment — an overlooked but critical step to generate tariff refunds.
It’s a common problem being seen for importers trying to claim an IEEPA tariff refund.
The first step is registering through the U.S. Customs and Border Protection’s ACE portal – the Automated Commercial Environment. But when you tried to register for ACE to get your tariff refund moving, you hit a wall right away because an account already exists tied to your Employer Identification Number (EIN).
You didn't set it up. Nobody currently at your company did either. And the ACE system has no capability in telling you who did.
Here's the part that's genuinely frustrating: Right now, someone other than you has control over your company's import account with the U.S. Customs and Border Protection (CBP). Until that gets resolved, there's no filing the refund.
If that's exactly where you are, call Frost Law at (410) 497-5947, and our team will get to work with CBP on identifying the account holder.
Ever since the Supreme Court's February 20, 2026 ruling in Learning Resources v. United States made IEEPA tariffs refundable, CBP has been running the CAPE process to get that money back to importers.
Those refunds go through the ACE portal as a CAPE Declaration, with payment made by an ACH transfer posted inside that same system, under the Electronic Refunds Interim Final Rule that took effect January 2, 2026. No access to the system means no filing, and no filing means no refund. The full chain is laid out in Frost Law’s special guide to ACE access problems.
Time and again, Frost Law finds the ACE account problems trace back to one of the same three sources:
Whoever it was is now your firm’s Trade Account Owner, or TAO, the person ACE considers the sole controller of that account.
That role doesn't sunset. It doesn't reset when an employee leaves or a broker relationship ends. It just stays locked to your EIN until someone formally changes it, which explains why a fresh registration is off the table. CBP's guidance specifically tells applicants to check for an existing top account first because the system rejects duplicate numbers tied to one identifier.
In the ACE system, no button exists to simply reclaim an account.
But there is a single self-service step worth knowing about, along with its real limits. Emailing ACE.Support@cbp.dhs.gov with "Trade Account Owner Lookup" in the subject line prompts CBP to contact whoever's on file as the TAO, and they'll let you know the outreach was sent.
That's as far as it goes. CBP contacts the owner directly, they won't tell you who that owner actually is. If that person is long gone from the company, or tied to a broker relationship you ended years ago, the message likely just disappears into an unread inbox, leaving you no further along than before, only with less time to spare.
CBP has automated a few pieces of account management recently, including, TAO reactivation that lets an active TAO manage other users on the account independently. None of that helps, though, when the TAO itself is the obstacle because you can't operate controls on an account that isn't yours to control.
What's actually required is a records-based process with CBP that pinpoints who currently holds the account, documents your company's rightful claim, and pushes CBP to reassign or rework the ownership. Every one of those is a formal request that needs the correct paperwork attached, and needs someone chasing it down afterward.
That chasing is usually where things break down. Requests go unanswered. Documentation gets requested once, then requested again. Because CBP alone can execute the actual change, the real skill is in knowing what to ask for and refusing to let the request go cold.
A stale Form 5106, the identity record CBP keeps on your company, can sink this same fix if it's also out of date. Frost Law covers that specific pitfall in our guide to updating Form 5106.
This is precisely the kind of problem-solving Frost Law does for refund clients as a matter of course. Find out if your imports qualify for an IEEPA refund, and we'll take the account-ownership issue on with CBP directly.
Here’s another common pitfall: A closely related error appears when adding an importer sub-account, a duplicate EIN or duplicate tax identification message.
It's the same underlying issue in different clothing. Your EIN already exists somewhere in CBP's records. Sometimes it’s filed under a different suffix, and sometimes it’s attached to a name your company doesn't recognize. That's your cue that you're facing a records problem, not a typo.
The fix mirrors the unknown-account situation exactly: You need to determine what CBP actually has on file, then get it corrected.
Any year, an unclaimed account on your EIN would be worth resolving. This year, for importers seeking a refund, it's actively costing you money.
The deadlines involved don't slow down while you're tracking down a broker relationship from years ago. Once an entry liquidates or reliquidates, an 180-day window opens to file a protest.
If your entries have already finally liquidated, and a case at the Court of International Trade becomes necessary, two key dates matter:
Do nothing, and here's the result: The account stays under someone else's name, your window for filing keeps shrinking, and a refund your company has earned remains locked behind a login you can't use.
Use the form below to tell Frost Law the error you're running into, and we'll give you a straight answer on who's most likely holding your account and what it'll take to get it back. And you can also call us at (410) 497-5947 with other tariff questions.
