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.
Billions of dollars are at stake involving IEEPA tariff refunds, but there are key steps importers must take to unlock these refunds.
Frost Law is seeing multiple instances where importers are struggling with basic issues accessing information inside the ACE system – the Automated Commercial Environment – that’s managed by the U.S. Customs and Border Protection (CBP). That’s why the firm created this special guide to the ACE portal.
One of the common problems being seen involves sub-importer applications. If you're waiting on a sub-importer application right now, here's the number that matters: CBP has told Frost Law to expect four to six weeks to process, with four weeks being about as quick as our team has seen it move.
Inside that range, the application is probably fine. Outside it, specifically, past the six-week window with the same non-answer on every call, that’s a sign you're dealing with something that needs active follow-up, not just more patience.
Not sure where you fall? Call Frost Law at (410) 497-5947 and we'll walk through it with you.
Keep this mind: Every week without a sub-importer account is a week CBP has no banking information from you, meaning a week they literally cannot process your IEEPA refund payment, regardless of anything else being in order.
These refunds trace back to the Supreme Court's February 20, 2026 decision in Learning Resources v. United States, which found the IEEPA tariffs unlawful. CBP responded by building the CAPE process inside ACE, and it's currently processing refunds at real scale.
It's easy to dismiss a sub-importer account as bureaucratic overhead. It isn't.
CBP's own ACE Portal and ACH Refunds guidance states it directly: Any company that might be eligible for a refund needs both an ACE Portal account and an Importer sub-account. That’s because the sub-account is what authorizes ACH refund payments and lets you submit banking details to CBP.
Put simply, this account is your only way to see and manage your importer-of-record status inside the ACE system. Without it, that status technically exists, but it's invisible to you, unmanageable, and disconnected from any way for your business to receive payment.
No sub-account means no banking information on file with CBP, which means there's nowhere for a refund to go. The larger context for that is in our guide to ACE portal problems.
In short: This isn't a form sitting in a drawer somewhere. It's the missing link between you and your money.
Ask CBP for a status update about your case, and you'll hear "it's in the queue." That's an accurate statement, and it remains accurate for a long time.
What it conveniently leaves out is whether your application is actually progressing toward anything.
Based on what Frost Law has uncovered digging into this issue for clients, the usual culprit is a missing piece of information. And that’s one nobody bothers to flag. There’s no follow-up email, and no status update but just continued placement sitting in line.
Here's the trap: Nearly every importer we talk to is convinced their submission was accurate and complete. But there's no visible difference between a complete file sitting in the queue and an incomplete one sitting in the same queue. You genuinely can't tell from the outside.
CBP's default mode is typically silence. The agency rarely proactively contacts an applicant about a problem. We've come across one exception to that pattern — a rejection notice explaining that the current Account Owner must match the name listed under Point of Contact and Authorization on the application.
Getting that particular email is actually useful; it tells you precisely what to correct. But everybody else with different situations are left guessing, which is the whole reason a clear timeline matters here.
Two markers to watch in these situations to watch in these situations are four weeks and six weeks. But it’s important to make a distinction from another, different CBP timeframe, which involves refunds. These generally arrive 60 to 90 days after a CAPE Declaration is accepted, which is a distinct, later phase of the process.
The four-to-six-week figure applies specifically to the sub-importer application itself. Here are some key points to keep in mind:
Here are additional warning signs, regardless of where you are on that timeline: Hearing the identical script every time you call, with no real information about status or blocking issues, and you feeling confident your application was submitted correctly. That confidence is common and, unfortunately, meaningless, because CBP simply doesn't tell you when something's off.
If you're past six weeks and this sounds like your situation, reach out to our Frost Law team, and we'll investigate exactly where your application currently stands. We can also help you determine if your import qualifies for an IEEPA refund.
More calls to the CBP’s general help line asking about the application status won't accomplish anything new; by this point, you probably already know that from experience.
What actually works is sustained follow-up with repeated calls and emails until you get a specific, actionable answer rather than another status update or queue confirmation. You need one concrete fact about what's missing or what's wrong so that you can address it directly.
That follow-through itself is the easier part. But what’s harder is knowing exactly what to ask CBP about and to recognize a genuine answer versus a scripted response, which typically only comes from the experience of repeated calls. That distinction is often what separates a productive sixth phone call from a wasted one.
Once the actual problem is identified, fixing it is generally simple. The real difficulty was ever finding out what that issue was in the first place. And the internal process doesn't end there; someone still needs to verify the application keeps moving because a system that stayed quiet before has no reason to start speaking up now.
Every week without a sub-importer account is week lost, meaning the IEEPA payment can’t be processed. Deadlines are what turn a delay into a genuine cost. Once an entry liquidates or reliquidates, a 180-day protest window opens.
For entries that have already finally liquidated, where you might need to file your own case at the Court of International Trade. There are two key dates apply:
How long has your sub-importer application been sitting? Tell us in the form below, when you filed and what CBP has said. Frost Law will give you a clear read on its status and what it'll take to move forward.
For these and other tariff issues, you can also call the Frost team at (410) 497-5947.
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.
Billions of dollars are at stake involving IEEPA tariff refunds, but there are key steps importers must take to unlock these refunds.
Frost Law is seeing multiple instances where importers are struggling with basic issues accessing information inside the ACE system – the Automated Commercial Environment – that’s managed by the U.S. Customs and Border Protection (CBP). That’s why the firm created this special guide to the ACE portal.
One of the common problems being seen involves sub-importer applications. If you're waiting on a sub-importer application right now, here's the number that matters: CBP has told Frost Law to expect four to six weeks to process, with four weeks being about as quick as our team has seen it move.
Inside that range, the application is probably fine. Outside it, specifically, past the six-week window with the same non-answer on every call, that’s a sign you're dealing with something that needs active follow-up, not just more patience.
Not sure where you fall? Call Frost Law at (410) 497-5947 and we'll walk through it with you.
Keep this mind: Every week without a sub-importer account is a week CBP has no banking information from you, meaning a week they literally cannot process your IEEPA refund payment, regardless of anything else being in order.
These refunds trace back to the Supreme Court's February 20, 2026 decision in Learning Resources v. United States, which found the IEEPA tariffs unlawful. CBP responded by building the CAPE process inside ACE, and it's currently processing refunds at real scale.
It's easy to dismiss a sub-importer account as bureaucratic overhead. It isn't.
CBP's own ACE Portal and ACH Refunds guidance states it directly: Any company that might be eligible for a refund needs both an ACE Portal account and an Importer sub-account. That’s because the sub-account is what authorizes ACH refund payments and lets you submit banking details to CBP.
Put simply, this account is your only way to see and manage your importer-of-record status inside the ACE system. Without it, that status technically exists, but it's invisible to you, unmanageable, and disconnected from any way for your business to receive payment.
No sub-account means no banking information on file with CBP, which means there's nowhere for a refund to go. The larger context for that is in our guide to ACE portal problems.
In short: This isn't a form sitting in a drawer somewhere. It's the missing link between you and your money.
Ask CBP for a status update about your case, and you'll hear "it's in the queue." That's an accurate statement, and it remains accurate for a long time.
What it conveniently leaves out is whether your application is actually progressing toward anything.
Based on what Frost Law has uncovered digging into this issue for clients, the usual culprit is a missing piece of information. And that’s one nobody bothers to flag. There’s no follow-up email, and no status update but just continued placement sitting in line.
Here's the trap: Nearly every importer we talk to is convinced their submission was accurate and complete. But there's no visible difference between a complete file sitting in the queue and an incomplete one sitting in the same queue. You genuinely can't tell from the outside.
CBP's default mode is typically silence. The agency rarely proactively contacts an applicant about a problem. We've come across one exception to that pattern — a rejection notice explaining that the current Account Owner must match the name listed under Point of Contact and Authorization on the application.
Getting that particular email is actually useful; it tells you precisely what to correct. But everybody else with different situations are left guessing, which is the whole reason a clear timeline matters here.
Two markers to watch in these situations to watch in these situations are four weeks and six weeks. But it’s important to make a distinction from another, different CBP timeframe, which involves refunds. These generally arrive 60 to 90 days after a CAPE Declaration is accepted, which is a distinct, later phase of the process.
The four-to-six-week figure applies specifically to the sub-importer application itself. Here are some key points to keep in mind:
Here are additional warning signs, regardless of where you are on that timeline: Hearing the identical script every time you call, with no real information about status or blocking issues, and you feeling confident your application was submitted correctly. That confidence is common and, unfortunately, meaningless, because CBP simply doesn't tell you when something's off.
If you're past six weeks and this sounds like your situation, reach out to our Frost Law team, and we'll investigate exactly where your application currently stands. We can also help you determine if your import qualifies for an IEEPA refund.
More calls to the CBP’s general help line asking about the application status won't accomplish anything new; by this point, you probably already know that from experience.
What actually works is sustained follow-up with repeated calls and emails until you get a specific, actionable answer rather than another status update or queue confirmation. You need one concrete fact about what's missing or what's wrong so that you can address it directly.
That follow-through itself is the easier part. But what’s harder is knowing exactly what to ask CBP about and to recognize a genuine answer versus a scripted response, which typically only comes from the experience of repeated calls. That distinction is often what separates a productive sixth phone call from a wasted one.
Once the actual problem is identified, fixing it is generally simple. The real difficulty was ever finding out what that issue was in the first place. And the internal process doesn't end there; someone still needs to verify the application keeps moving because a system that stayed quiet before has no reason to start speaking up now.
Every week without a sub-importer account is week lost, meaning the IEEPA payment can’t be processed. Deadlines are what turn a delay into a genuine cost. Once an entry liquidates or reliquidates, a 180-day protest window opens.
For entries that have already finally liquidated, where you might need to file your own case at the Court of International Trade. There are two key dates apply:
How long has your sub-importer application been sitting? Tell us in the form below, when you filed and what CBP has said. Frost Law will give you a clear read on its status and what it'll take to move forward.
For these and other tariff issues, you can also call the Frost team at (410) 497-5947.
