A common misconception is that only US-based businesses can recover US import duties. That is not how the statute works. Under US customs law, the importer of record is the entity in whose name an entry was filed — and that entity is not required to be a US person. Foreign businesses that paid IEEPA tariffs on goods entering the United States in 2025 and 2026 are just as entitled to refunds as their US counterparts. What differs is the procedural friction involved in claiming them.
This post is aimed at importers who are based outside the United States and are trying to figure out how to actually claim a refund on duties they paid under IEEPA authority. We will cover the five real obstacles, how each can be addressed, and where Tariff Spot fits.
Obstacle 1: CBP needs somewhere to send the decision
When an importer files a protest, CBP issues a decision — approved, denied, or denied in part. The decision arrives by mail, at the address the importer provides in the notice section of Form 19. For a non-US importer without a US address, that field is a problem. Sending CBP decisions to an address in, say, Shenzhen or Rotterdam adds weeks to any timeline and introduces the risk that the decision letter never gets opened.
The practical solution is a US address that can receive physical mail and forward the contents digitally. A virtual mailbox at a US location, operated by a provider that scans incoming post, fulfils the requirement for CBP notice purposes and removes the international delivery friction. Tariff Spot uses its own US business address for this purpose on behalf of non-US customers — decisions arrive at our Casper, Wyoming address, we scan the letter, we forward it to the importer by email the same day.
Important nuance: the address on Form 19 is a legal address for CBP’s communications. It does not convert the importer into a US entity. The importer of record remains the foreign business, and the refund remains owed to them.
Obstacle 2: Refunds move over ACH — which needs a US bank account
Since February 6, 2026, CBP has been required to issue all refunds electronically via ACH. This rule flows from an Interim Final Rule implementing Executive Order 14247 and applies uniformly to US and foreign importers alike. The rule text is explicit: paper cheques are no longer the default, and refunds that cannot be disbursed electronically sit without accruing interest until valid banking information is provided.
For a non-US importer, this is the hardest obstacle, because ACH is a US domestic payment system. To receive an ACH credit from CBP, an importer needs a US bank account with an account number and routing number. The options are:
- Open a US business bank account — most viable for foreign importers that already operate in the US market at any meaningful scale, often through a US subsidiary or branch.
- Use a third-party receiver of funds — a licensed customs broker or trade attorney who can receive the refund on the importer’s behalf and forward it onward, subject to their own compliance and engagement terms.
- Apply for a narrow regulatory waiver — under 31 C.F.R. § 208.4, Treasury can waive the electronic refund requirement in very narrow circumstances. The criteria are strict — one provision addresses countries where the local banking infrastructure does not support electronic funds transfer, which in practice excludes most major economies. Treasury has said publicly that it expects waivers to be rare, and the burden of demonstrating eligibility sits entirely with the importer.
We cover the ACH question in detail in the ACH enrollment guide, including what the enrollment form actually asks for and why the waiver path is not the escape hatch many coverage pieces suggest.
Obstacle 3: The protest has to be filed at a specific US port
Under 19 C.F.R. § 174.12, a written protest must be filed at the port where the entry was made. For a US importer, this is usually just a mailing question. For a non-US importer, it means posting a physical document from overseas to a specific CBP address, in the correct format, within a strict deadline — all the while hoping the international post delivers on time.
International mail to a CBP port office from outside the US is a real source of risk. Customs clearance on the outbound side, lost or delayed parcels, and the simple fact that the importer cannot verify receipt without tracking through a foreign postal partner all compress the working window. This is one of the places where a US-based printing and mailing partner becomes a significant risk reduction: the protest is printed and posted domestically, inside the United States, with a First Class US Mail timeline the importer can plan around.
Tariff Spot’s model is built around this. We generate the protest, we print and mail it from within the US in the format the regulation requires, and we keep records of when it went out. The importer never has to touch international post.
Obstacle 4: ACE portal access requires a US presence
CBP’s Automated Commercial Environment portal (ACE) is the electronic alternative to paper filing, and in many contexts it is the preferred route for US-based importers. For non-US importers without a US presence, ACE is often unreachable — account provisioning effectively assumes the importer is a domestic operator with the infrastructure to register, authenticate, and maintain access.
The relevant legal point is that paper filing on Form 19 remains fully valid under 19 C.F.R. § 174.12(b). ACE is an alternative, not a replacement. A foreign importer who cannot practically obtain ACE access loses nothing substantive by filing on paper — the paper filing is the legal baseline, and the regulation explicitly contemplates it as a standard method.
Obstacle 5: Time zones and paper deadlines
The final friction is mundane but real. A jurisdictional 180-day deadline applies in Eastern Time, on a US business calendar. Federal holidays shift deadlines. Time zones change when the working day ends. For an importer eight or twelve hours off US East Coast time, a protest that needs to be mailed “before the deadline” is easy to leave until it is actually too late.
Working from a US-based operator removes the time-zone risk. The entries are triaged on US time, the protest goes to post on US time, and the deadline is enforced against the same clock CBP enforces against.
A non-US importer’s practical checklist
- Confirm the importer of record on each entry. For some arrangements, the legal importer is a US subsidiary rather than the foreign parent — the refund is owed to the subsidiary, not the parent. Check before filing.
- Get the liquidation date for every affected entry. Your customs broker has this information regardless of where you are based.
- Solve the US address problem first. You need a real US address that can receive physical mail. Your broker may offer one; a virtual mailbox is the common alternative.
- Start the ACH enrollment process in parallel. This is the hardest obstacle and the one that, if ignored, will prevent you collecting a refund even if CBP approves it. The enrollment is not needed at the moment of filing, but it needs to be resolved before the refund is disbursed.
- File the protest on urgent entries. Do not wait for CAPE. The 180-day deadline does not care which refund channel you eventually use.
Where Tariff Spot fits
Tariff Spot was built with non-US importers specifically in mind. Half of the frictions in this post — the US address for CBP notices, the US-based printing and mailing of the protest, the correctly formatted Form 19, the port routing — are things Tariff Spot absorbs as part of a flat per-entry fee. You remain the importer of record, you sign the generated Form 19, and we handle the US-side logistics.
The one thing we cannot do for you is provide the US bank account. That is a regulatory constraint on the ACH side, not a Tariff Spot limitation, and it applies equally to every refund channel CBP is building. A foreign importer who wants to recover IEEPA duties will need to solve the ACH question independently — whether through a US subsidiary, a third-party receiver, or the narrow waiver path.
If you are a foreign importer with IEEPA exposure on your 2025 entries and want the US-side filing work handled for you, start a refund claim. The form surfaces ACH guidance inline as you go.