Unlock Your Section 9903 Tariff Refund Today.
The Supreme Court ruled in your favor, but the U.S. Treasury could take 6 months to pay. We legally secure your expiring entries and advance your capital in 2 to 3 weeks.
Entries liquidated in Q4 2025 — 180-day protest deadline under 19 U.S.C. § 1514
48-Hour Term Sheet Timeline
From your first upload to a wire transfer in your account — here is exactly what happens and when. Click any stage to see the full detail.
Following the Supreme Court's February 20, 2026 ruling on IEEPA tariffs, U.S. importers are eligible to recover previously paid duties. CBP is constructing the CAPE system — but payouts are months away.
Source: U.S. Customs and Border Protection data on Congress.gov, referenced February 20, 2026
Understanding Your Eligibility
Your refund strategy depends entirely on your entry's liquidation status. Use the matrix below to identify your position.
- No protest required — CAPE automation handles these
- Highest-quality asset class for advance structuring
- 80–85% advance available through Pilothouse's network
- Interest clock has not yet started
- Formal protective protest must be filed immediately
- 180-day window from liquidation date applies
- 70–75% LTV advance available (contingent on protest)
- Entries past 180 days currently excluded from CAPE
Who Is the Importer of Record?
Your shipping terms determine who paid the duties — and therefore who can claim the refund. Confirm your Incoterm before filing.
| Term | Who is the IOR? | Can They Claim a Refund? |
|---|---|---|
| DDP(Delivered Duty Paid) | The Seller | No (Usually) |
| DAP(Delivered at Place) | The Buyer (Your Client) | Yes |
| FOB(Free on Board) | The Buyer (Your Client) | Yes |
Note: Under DDP terms, the foreign seller is typically listed as the Importer of Record and paid the duties — making them the party eligible to claim the refund, not the U.S. buyer. Consult your customs broker to confirm your IOR status before proceeding.
Asset Recovery Matrix
Per the Eaton Order (Atmus Filtration, Inc. v. United States, CIT Mar 4, 2026), entries are classified into three tiers based on liquidation status and protest window.
| Tier | Status | Days Since Liquidation | Required Action | Eligibility | Advance Rate |
|---|---|---|---|---|---|
Tier 1 | Unliquidated | N/A | CAPE Auto-Processing | Highest Liquidity | 80–85% |
Tier 2 | Liquidated < 180 Days | < 180 Days | File Protective Protest Now | At Risk — Act Now | 70–75% LTV |
Tier 3 | Final Liquidated > 180 Days | > 180 Days | Pending Further Court Guidance | Excluded | Not Available |
Important: The 180-day protest window is a hard deadline under 19 U.S.C. § 1514. Pilothouse is not a licensed customs broker or attorney and cannot file protests on your behalf. Pilothouse prepares documentation and coordinates with your Broker of Record who executes the filing.
The CBP Path vs. The Pilothouse Path
CAPE is under construction. Every day of delay is accruing interest — but your capital is still locked in the Treasury.
4–9 months for actual payout
Capital provider funds your account in 48 hours
CAPE Portal: Phase 1 launch late April 2026
Instant Audit: ACE CSV analysis in minutes
Manual CBP review may trigger additional audits
We prepare Protest documents; your Broker of Record files them
You must set up ACH independently (required for refund)
ACH setup coordination included in advance package
Manual review of each entry line item
Pilothouse A³ scans all entries; filters 9903 vs. Section 122
Requires licensed customs broker or attorney
Pilothouse prepares; your Broker of Record executes the filing
| Feature | The CBP Path (Wait) | The Pilothouse Path (Now) |
|---|---|---|
| Timeline to Liquidity | 4–9 months for actual payout | Capital provider funds your account in 48 hours |
| Portal Status | CAPE Portal: Phase 1 launch late April 2026 | Instant Audit: ACE CSV analysis in minutes |
| Audit Risk | Manual CBP review may trigger additional audits | We prepare Protest documents; your Broker of Record files them |
| ACH Enrollment | You must set up ACH independently (required for refund) | ACH setup coordination included in advance package |
| HTS 9903 Identification | Manual review of each entry line item | Pilothouse A³ scans all entries; filters 9903 vs. Section 122 |
| Protest Filing | Requires licensed customs broker or attorney | Pilothouse prepares; your Broker of Record executes the filing |
From Upload to Wire Transfer in 48 Hours
The Pilothouse A³ process is designed to be the fastest, most compliant path to IEEPA refund liquidity available today.
Connect
Securely upload your ACE Entry Summary (CSV) or 7501 PDFs. Our encrypted portal reads Entry_Number, HTS_Number, Duty_Paid_Amt, and Liquidation_Date automatically.
Verify
Pilothouse A³ Technology (Audit. Architect. Align.) instantly identifies all 9903-type IEEPA line items, applies the 180-Day Wall matrix, and calculates your total eligible duties.
Fund
Sign the Advance Agreement facilitated by Pilothouse. Our capital provider network funds your wire transfer. Pilothouse coordinates CBP protest filings (Form 19), ACH enrollment, and 7501 vetting throughout the process.
340+
Importers Facilitated
Across 28 industry verticals
$2.1B
Duties Identified
Via Pilothouse A³ Technology
48 hrs
Average Wire Time
Capital provider to importer
IEEPA Refund Timeline
From Tariff Imposition to Refund Window
Feb 2025
IEEPA TariffsImposed
May 2025
Court RulesUnlawful
Feb 2026
Supreme CourtRuling
Now
Refund ClaimWindow Open
180-Day Protest Window
For liquidated entries, importers typically have 180 days from the date of liquidation to file a formal protest with U.S. Customs.
Statute of Limitations
Litigation-based refund claims are subject to separate statute of limitations under 28 U.S.C. § 2636. These timelines vary based on claim type.
Unliquidated Entries
Entries that have not yet liquidated may offer the broadest recovery options, including Post-Summary Correction before final assessment.
How the CAPE Process Works
Four steps from raw ACE data to funded advance. No cost to evaluate.
Data Normalization
Upload your ACE Entry Summary CSV. Our A³ system normalizes HTS codes, flags all 9903-type IEEPA line items, and separates them from Section 122 entries.
CAPE-Ready Export
We generate a protest-ready schedule with entry numbers, duty amounts, liquidation dates, and 180-day status for each entry — formatted for your Broker of Record.
Protective Filing Assistance
Pilothouse prepares CBP Form 19 documentation and coordinates with your licensed customs broker or attorney to file protective protests before the 180-day deadline.
Immediate Bridge Funding
Once entries are verified and protest filed (if required), Pilothouse arranges the advance through its capital provider network. Wire transfer within 48 hours.
Compliance & Regulatory Notices
Federal refunds cannot be assigned to a third party before issuance. All Pilothouse advances are structured as secured bridge loans — CBP refunds must flow to the Importer of Record's ACH account.
Only the Importer of Record, their licensed customs broker, or an attorney may file a protest under 19 U.S.C. § 1514. Pilothouse prepares documentation but cannot file protests directly.
If IEEPA duties were passed through to customers, the economic burden test under 19 U.S.C. § 1520(d) may affect eligibility. Importers must certify they bore the economic burden.
CBP mandates ACH enrollment for all IEEPA refunds as of March 2026. Paper checks are no longer issued. Pilothouse provides ACH setup coordination as part of the advance package.
The CBP interest rate is Treasury-determined and subject to quarterly adjustment. All rates shown are illustrative only. Current estimated rate is approximately 3.5% per annum.
Not all tariffs are IEEPA-eligible. Section 122 tariffs (HTS 9903.88.XX) are distinct from IEEPA §9903.01.XX duties. Pilothouse's A³ scanner filters these automatically.
How Much Can You Recover?
Enter your estimated IEEPA tariff spend and liquidation date. Our calculator applies the exact 180-Day Wall logic to show your CBP payout, statutory interest, the advance amount available through our capital provider network, and days until forfeiture.
Up to 75% LTV Advance Rate
Our capital provider network advances up to 80 cents on every dollar of your estimated CBP refund, wired within 48 hours of signing the facilitated agreement.
CBP Statutory Interest Included
CBP pays statutory interest on refunded duties per 19 U.S.C. § 1505(c) at a rate set quarterly by the U.S. Treasury. Our calculator uses an illustrative rate for estimation purposes only.
Real-Time 180-Day Analysis
The calculator uses today's date to compute exactly where your entries stand in the Asset Recovery Matrix.
Dynamic CTA Based on Status
Qualified entries are matched with a capital provider for a standard advance. Critical window entries trigger emergency filing coordination. Expired entries route to legal review.
IEEPA Refund Calculator
180-Day Wall analysis · CBP interest included · Pilothouse is an intermediary
Enter your §9903 duty amount above to calculate your advance
CBP ACH Enrollment Required to Receive Your Refund
As of March 2026, CBP no longer issues paper checks. You must enroll your bank account via the ACE portal before any IEEPA §9903 refund can be disbursed. Pilothouse provides ACH enrollment coordination as part of our advance service.
Upload Your ACE Entry Summary for Instant Analysis
Our Pilothouse A³ parser reads your ACE CSV export using the exact CBP column headers — Entry_Number, HTS_Number, Duty_Paid_Amt, Liquidation_Date — and applies the 180-Day Wall matrix to every entry in seconds.
What the Auto-Scan Detects:
Data Privacy Guarantee
Your ACE data is processed locally in your browser and never transmitted without your explicit consent. SOC 2 Type II certified.
ACE Entry Summary Auto-Scan
9903 filter · NULL handler · Daily interest formula · Protest Schedule export
Drop your ACE Entry Summary (.CSV) here
or click to browse · .csv format only
CAPE & IEEPA News
Curated updates from authoritative legal and trade publications · Updated March 2026
CBP Provides Further Details on IEEPA-Related Refund Mechanism
CBP filed a second progress report confirming the CAPE system's phased rollout. The Refund component is now approximately 60% complete. CBP confirmed ACH enrollment is mandatory — thousands of importers are currently blocked from receiving refunds due to missing ACE enrollment.
CBP CAPE Refund System Update: Four-Phase Rollout Confirmed
CBP's March 19 court filing confirmed the CAPE system will deploy in four phases: (1) Claim Portal in ACE, (2) Mass Processing of unliquidated entries, (3) Review & Reliquidation of liquidated entries, and (4) Refund issuance. Phase 1 portal launch expected late April 2026.
IEEPA Tariff Refunds: Current Status and Next Steps for Importers
JD Supra analysis confirms that importers with liquidated entries must file protective protests under 19 U.S.C. § 1514 within 180 days of liquidation. Entries that are 'final and conclusive' (past the protest window with no protest filed) are currently excluded from the automated CAPE process.
Is Your ACE Enrollment Blocking Your IEEPA Tariff Refund?
Since February 6, 2026, CBP transitioned to an all-electronic refund system. ACE enrollment and ACH setup are now required to receive any electronic payment from CBP — including IEEPA refunds. There is no paper check alternative. Importers must confirm enrollment immediately.
U.S. Customs Files Update: Tariff Refund Process In Progress
On March 6, CBP filed a declaration requesting a 45-day extension for ACE system updates to handle the massive volume of refund processing. CBP confirmed that the March 4 CIT order remains stayed pending completion of the CAPE system build.
U.S. CBP Provides Update on IEEPA Duty Refund Process
CBP is developing new ACE functionality to automate and centralize IEEPA tariff refund claims. The CAPE system will allow importers to upload CSV files of their entries directly through a new 'CAPE' tab in the ACE Portal. CBP estimates the Refund component is 60% complete as of March 11.
News Disclaimer: The above items are curated summaries from publicly available legal and trade publications for informational purposes only. Pilothouse Structured Debt Finance (a DBA of Rhino Consulting LLC) does not author or endorse these third-party publications. This content does not constitute legal, tax, or financial advice. Consult a licensed customs broker or attorney for guidance specific to your entries. Contact Pilothouse at 800.507.3557 or www.pilothouse-sdf.com.
Frequently Asked Questions
Don't Let Your Refund Rights Expire
Every day without a protest filing is a day closer to permanent forfeiture. Pilothouse has helped importers identify over $2.1 billion in IEEPA duties and connect them with capital providers. Start your facilitated advance today.