CBP Refunds Are Moving to ACH: What Importers Need to Know
- Adam C
- Jun 30
- 6 min read
Customs refunds are changing. U.S. Customs and Border Protection now issues refunds electronically through Automated Clearing House, commonly called ACH, subject to limited exceptions. This change affects importers, customs brokers, suppliers, sureties, drawback claimants, foreign trade zone operators, and other parties that may receive customs related refunds from CBP.
For importers, this is not just an accounting update. It is a compliance, banking, authorization, and fraud prevention issue. If your company expects to receive a refund from CBP, you should make sure your ACE Portal access, importer record, tax identification information, and bank account information are correct before a refund is ready to be issued.
CBP’s interim final rule on electronic refunds became effective on February 6, 2026. The rule states that, subject to limited exceptions, CBP will issue refunds electronically rather than by paper check.
What is an ACH refund from CBP?
An ACH refund is an electronic deposit from CBP into an authorized U.S. bank account. CBP uses ACH refunds for overpayments of customs duties, taxes, fees, and certain other payments submitted to CBP. Once properly enrolled, the refund is deposited directly into the bank account listed for the refund recipient.
In plain English, this means CBP is moving away from mailing paper Treasury checks and toward electronic refund deposits.
CBP has explained that ACH refunds help reduce delays and risks associated with paper checks, including fraud, lost mail, and undeliverable addresses.
Why importers should pay attention
Many importers only think about customs payments when duties are owed. But refunds can be just as important. Refunds may arise from liquidation changes, post summary corrections, protests, drawback, reliquidations, tariff exclusions, overpayments, administrative corrections, or other CBP actions.
If the refund is significant, an incorrect banking setup can create real problems. A company may experience delays, rejected payments, internal accounting confusion, or disputes over who was legally entitled to receive the funds.
That is why importers should review the refund process before the refund is issued.
How importers enroll for electronic refunds
CBP directs companies to use the ACE Secure Data Portal to manage ACH refund information. Companies generally need ACE Portal access with the importer account view. Within that view, authorized users can access the ACH Refund Authorization tab to add, view, or update bank information.
CBP has also stated that companies without ACE Portal access should make sure their CBP Form 5106 importer record is current and includes a valid company email address. CBP specifically states that the email address should not be the broker’s email address.
This is an important point. The importer should maintain control over its own importer identity, company email, ACE access, and banking authorization.
Who should receive the refund?
As a general rule, the refund should go to the party legally entitled to receive it. In many cases, that will be the importer of record because the importer of record is the party responsible for the entry and the party associated with the duties, taxes, and fees paid to CBP.
However, real world transactions can be complicated. A supplier may have reimbursed the importer. A related company may have paid the duties. A broker may have advanced funds. A customer may have contract rights to the refund. A foreign supplier may ask that the refund be deposited to another party’s bank account.
Those situations should not be handled casually. Before changing refund banking instructions or routing a refund to a third party, the parties should have proper written authorization, clear accounting records, and a complete understanding of who owns the refund.
Can a customs broker receive a refund on behalf of an importer?
In some circumstances, a broker or other party may be listed as a refund recipient or notify party, but that does not mean it is automatically appropriate in every case. CBP materials refer to parties that may receive refunds on behalf of importers through CBP Form 4811 notify party arrangements, and CBP has included those parties in its electronic refund enrollment guidance.
From a practical standpoint, a customs broker should be careful before agreeing to receive a refund that belongs to another party. Important questions include:
Who is the importer of record?
Who paid the duties, taxes, and fees?
Who is legally entitled to the refund?
Is there a valid power of attorney?
Is there a written authorization for the broker or other party to receive the funds?
Does the broker have internal controls to identify, segregate, account for, and remit the refund?
Could the arrangement create a dispute between the importer, supplier, customer, or broker?
Could the bank account change create fraud, money laundering, or business email compromise risk?
A broker should not treat a customs refund as ordinary inbound cash. A refund can involve fiduciary responsibilities, accounting controls, and legal obligations.
What TRIO Customs Brokers can do
TRIO Customs Brokers can help importers understand the customs side of the refund process. That may include reviewing entry information, identifying the importer of record, helping determine whether an entry may be eligible for refund review, assisting with post entry questions, and helping the importer understand what CBP documentation may be needed.
TRIO can also help importers understand the importance of keeping the CBP Form 5106 importer record current, including company name, address, tax identification information, and appropriate contact information.
If an importer has questions about ACH refund enrollment, TRIO can help explain the process and point the importer to CBP’s ACE Portal guidance. However, the importer should maintain appropriate control over its own banking information and ACE Portal access.
What TRIO Customs Brokers cannot do
TRIO cannot decide ownership of a refund when multiple commercial parties disagree. TRIO cannot provide legal advice about contract rights between an importer, supplier, customer, or related company. TRIO also cannot accept or redirect refund funds without appropriate documentation and authorization.
In many cases, the safest process is for the refund to be deposited directly into the rightful recipient’s authorized bank account through CBP’s ACH refund process. If another arrangement is requested, it should be supported by clear written instructions, proper authorization, and, when appropriate, legal or accounting review.
Documentation importers should gather
Importers expecting a CBP refund should gather and organize the following:
Importer of record number
Current CBP Form 5106 information
ACE Portal access details for authorized company users
Company tax identification information
U.S. bank account and routing information for refund deposits
Entry numbers related to the refund
Proof of duty, tax, and fee payment
Commercial invoices, packing lists, bills of lading, and entry summaries
Any post entry filings, protests, liquidation notices, exclusion claims, drawback claims, or CBP correspondence
Written authorization if a third party is involved
Internal accounting records showing who paid the duties and who should receive the refund
Common mistakes to avoid
The first mistake is waiting until the refund is ready before checking ACH enrollment. If the refund recipient is not enrolled properly, payment may be delayed or rejected.
The second mistake is using the broker’s email address or another third party email address as the importer’s main CBP contact. CBP has specifically warned that companies should not use the broker’s email address for the importer record email needed for ACE Portal authentication.
The third mistake is assuming the party that asks for the refund is automatically the party entitled to receive it. Refund ownership should be confirmed through entry records, payment records, contracts, and written authorization.
The fourth mistake is changing bank instructions based only on email. Refund fraud and business email compromise are real risks. Bank changes should be verified through trusted channels and approved by authorized personnel.
The fifth mistake is failing to reconcile the refund after receipt. Importers should match the ACH deposit to the correct entry, refund reason, accounting period, customer, supplier, and internal duty account.
Common ACH Delay Drivers
Practical checklist for importers
Before a CBP refund is expected, importers should take the following steps:
Confirm the importer of record.
Confirm the company’s CBP Form 5106 record is accurate.
Confirm the company has ACE Portal access with the importer account view.
Confirm the correct authorized users can access the ACH Refund Authorization tab.
Confirm the company’s U.S. bank account information is accurate.
Confirm who is legally entitled to the refund.
Confirm whether any third party authorization exists.
Review internal controls for bank changes and refund approvals.
Monitor refund activity through ACE Reports when available. CBP guidance identifies the REV 603 Trade Refund report for successful refunds and the REV 613 ACH Rejected Refunds report for refunds rejected because the recipient was not enrolled in ACH refunds.
Reconcile the refund after deposit.
Bottom line
CBP’s move to electronic ACH refunds should make refunds faster and safer when the importer’s records are correct. But the process also puts more responsibility on importers to maintain accurate ACE Portal access, banking information, authorization records, and internal controls.
A customs refund should not be treated as a simple payment issue. It should be treated as a customs compliance and financial control issue.
TRIO Customs Brokers can help importers review the customs information connected to a refund, understand the ACH refund process, and identify documentation gaps before they create delays or disputes.
For importers expecting refunds from CBP, the best time to review ACH setup is before the refund is issued.
Comments