That assumption came from a June 4 declaration. U.S. Customs and Border Protection said international postal refunds present unique problems because those shipments were not entered in the Automated Commercial Environment. The agency also said third parties collected duties from senders and remitted the money to CBP, leaving the agency without the information or ability to repay the people who funded the payments.
Zonos says in the brief that its customer records supply the information CBP is missing and that it can facilitate repayment. The company was among the parties CBP certified to collect and pay duty on international mail. According to the report, Zonos collected millions of dollars in IEEPA tariffs from customers and remitted the money to the government.
Zonos's filing puts a narrower factual question before the court. CBP lacks an ACE entry number for each package, but it required a separate package record for each shipment.
CBP's own collection design points to an alternative. The agency required carriers and qualified parties to report package-level data on International Mail Duty Worksheets. Those records included the tracking number, arrival port and date, country of origin, tariff rate, duties owed, and declared value when the ad valorem method applied. A qualified party's customer record may add the identity of the person or business that supplied the tariff payment. Refunds may therefore turn on a verified match between two existing files rather than a conventional customs entry that never existed.
For a limited data-matching test, Zonos would not need to establish that a qualified party was an importer of record. It would need to show that its customer files supply the identity missing from CBP's worksheet. A controlled test could resolve that factual question without deciding who owns or may pursue the refund claim.
Postal duties were built on a separate ledger
The postal collection system was deliberately placed outside the ordinary entry path. Executive Order 14324 provided that covered postal shipments would move without preparation of an entry until CBP created a new process. Carriers or qualified parties acting in their place had to collect and remit the duties. CBP's implementation message repeated that no entry would be prepared for those shipments under the interim process.
CBP still required a package-level accounting outside ACE. Its Global Guidance for International Mail required a monthly worksheet and payment through Pay.gov. The first page carried the collection methodology, package count, and total duty. The second page listed the individual postal items.
For each item, the worksheet called for a mail tracking number. It also called for the conveyance, arrival port, arrival date, declared value when the ad valorem method applied, country of origin, tariff rate, and duties owed. CBP reserved the right to audit the spreadsheet and individual package count through physical verification or electronically through ACE.
That is a customs record, even though it is not an ACE entry summary. It can show that a particular package was included in a particular monthly remittance and that a stated amount of duty was associated with it. The qualified party's own records can then show who was charged, how much was collected, whether the amount included a service fee, and whether any later credit was issued.
The declaration describes an information gap at CBP, but the interim program itself divided the relevant records. CBP received the package data and monthly remittance. A qualified party may hold the customer and payment history, as Zonos says it does. A refund process has to reconcile both without duplicating claims, overstating principal, or paying the wrong person.
The tracking number can connect the two files
The tracking number is the obvious bridge, but a reliable match needs a composite key. The key can combine the qualified party or carrier identifier, reporting month, tracking number, arrival date, and package duty amount. A package with goods from more than one origin also needs a line sequence or another stable way to reconcile the component duty rows.
Tracking numbers are not unique enough on their own. They can be mistyped or reused. One payment can cover several packages, and one package can contain goods from several origins. Customer invoices may also combine duty with service fees, postage, or currency conversion. Cancellations and later credits create another source of error. A composite key catches cases that a tracking-number-only match would miss.
Reconciliation should start with the amount CBP received, not the customer's invoice total. Once the worksheet row is tied to the monthly payment and any correction, that row sets the provisional ceiling. The customer ledger then identifies the payment that funded it. Service fees, foreign taxes, postage, currency conversion, and later adjustments remain outside the federal duty refund absent a separate legal basis.
The records distinguish four parties who may not be the same. The qualified party is the remitter. Its account holder may be a merchant, postal operator, or shipping platform. The named sender appears in the postal transaction. The ultimate economic bearer may be a buyer who reimbursed the seller through the purchase price. The current record supports an effort to repay the person from whom the IEEPA amount was collected. It does not prove that the sender in every postal label was the final economic bearer or the legally entitled claimant.
The test therefore needs both a payer field and a proposed beneficiary field. If they differ, the record needs the contract, refund term, or assignment that explains the difference. That step answers CBP's concern about enriching a collector rather than repaying the person who funded the duty.
CBP's July 24 rule keeps the worksheet at the center
The new postal informal entry process generally takes effect on July 24, 2026, the same day comments close. The regulatory baseline remains a monthly International Mail Duty Worksheet submitted by email with payment through Pay.gov. The rule adds the filer code, bond number, merchandise description, ten-digit tariff classification, quantity or weight when required, and other fields to the package data already collected. Separate formal-entry requirements for certain regulated, Chapter 98, Chapter 99, and trade-agreement shipments have an October 22 compliance date.
CBP's continued use of the monthly spreadsheet shows that the agency considers tracking-number worksheets administrable for postal duty collection. The worksheet can document collection, but it cannot identify the proper refund beneficiary without a payer file and an entitlement rule.
CBP is also preparing a second prospective option. A separate June 24 notice says a voluntary ACE Entry Type 13 test for eligible future international mail will begin on September 22. The rule preamble says the opening will coincide with the October 22 end of the delayed-compliance window, leaving a one-month discrepancy for CBP to clarify. Both paths are prospective. Neither retroactively assigns entry numbers to packages that paid IEEPA duties under the interim worksheet regime. The rule also changes who may file going forward. Those limits prevent the new framework from deciding the refund question by itself.
The legacy worksheet contains enough fields to test a match. It already had tracking number, arrival, value when required, origin, rate, and duty. The new version adds classification, filer, bond, description, and quantity fields. A postal refund annex could use the older fields while borrowing the newer checks.
Using a compatible format would let CBP compare historical and prospective records. The agency could flag a tracking number that appears in both periods, identify a later correction, and preserve one package history without treating the older record as an ACE entry.
CAPE asks the wrong identifier for postal refunds
The current Consolidated Administration and Processing of Entries system begins with an ACE entry number. CBP's April 13 deployment guidance tells an importer of record or authorized broker to upload a file of entry numbers. CBP validates the numbers, confirms the filing relationship, and processes accepted entries through liquidation or reliquidation. The entry is both the unit of legal treatment and the database key.
An interim postal package has no such number. Requiring one adds no evidence and asks the claimant to invent a record that the government expressly chose not to prepare. A postal refund channel can preserve CAPE's controls while changing the primary identifier.
CAPE could add a postal annex keyed to the monthly worksheet. CBP would match the remitter, reporting period, Pay.gov receipt, tracking number, arrival data, origin, value, rate, and duty. Only matched rows would proceed to a separate check of the payee.
The government worksheet and payment record would cap the principal once CBP confirms that the row was received and reconciled. The customer record would name the payer. A mismatch, duplicate, or excess claim would stop that row. A package absent from the government worksheet would remain outside the batch unless another official record established payment.
The primary key changes, but the legal and beneficiary questions do not disappear. CBP would still require an official record, an authorized submitter, an identified recipient, and a duplicate-payment check.
The older international mail protest procedure offers a limited comparison. CBP described the mail addressee as the importer and listed documentary protest options after duty assessment, including a formal mail protest using the mail entry form and an administrative protest under 19 U.S.C. 1514. The CBP article still states a 90-day filing period. Current section 1514(c)(3), however, generally requires a protest within 180 days after liquidation or, when that measure does not apply, the protested decision. The article's 90-day statement should therefore be treated as legacy guidance, not the current statutory deadline. That history leaves refund entitlement unresolved, but it shows that postal disputes have not always depended on the same filer relationship as ordinary commercial entries.
A postal annex has to follow the money through three records
Any pilot has to reconcile three ledgers. CBP's worksheet and Pay.gov records establish what the government received. The collector's account history identifies who paid, separates duty from postage and platform fees, and shows any reversal. The submitter should also attest that the claim has not been assigned, refunded, or submitted elsewhere.
The final disbursement record should show the beneficiary, amount, payment status, and supporting evidence when payer and beneficiary differ. CBP and the court can receive aggregate reports while retaining audit access to row-level records.
With court authorization and a legal basis for disbursement, an intermediary could move validated funds without owning the refund claim. Disputed rows can be held back while the rest of the batch proceeds. Unclaimed or undeliverable funds need an explicit retention and escheat rule, not silent reversion to the collector.
Qualified parties could pass funds without owning the claim
Zonos relies on the registration and bond requirements that applied to qualified parties. CBP guidance identifies the registration document as Form 5106 and permits a single-transaction or continuous basic importation and entry bond. Those facts establish CBP registration, remittance liability, and a bond protecting the government's revenue. They do not establish beneficial ownership of a refund or protection for customer funds. They also do not answer whether a qualified party can exercise every right reserved to an importer of record.
The distinction became sharper in CBP's June 24 postal rule. For the new postal informal entry process, CBP limited filing to parties with the right to make entry under its regulations. That means an owner or purchaser, or a licensed customs broker properly designated by an owner, purchaser, or consignee. The preamble recognizes that some nonbroker qualified parties used the interim process, while the new rule limits future filing to parties with the right to make entry.
That weakens the claim that qualified-party status automatically carried importer-of-record rights. Zonos's data may still matter even if its status does not.
A court-approved pass-through mandate would fit the narrower role. The intermediary would receive funds only for validated rows and hold them in a segregated account. It would pay validated beneficiaries within a fixed period, provide itemized notices, report failed payments, and preserve unresolved funds under stated rules. It could deduct no fee from principal or interest unless the customer agreement and court order expressly permitted it.
The plan also has to survive the vendor. The refund process may outlast a contract or the intermediary itself. CBP would need a data export and escrow arrangement sufficient to complete payments if a company becomes insolvent, loses certification, or exits the market. A bond may protect government revenue during collection without protecting customer refunds later.
The record still has material gaps
Zonos's July 8 brief is a representation, not an audit report. It says the company has the information and ability to pay senders. The filing omits the coverage rate, field definitions, exception count, retention period, and number of packages that can be matched without manual work. The claim is testable, but the current public record leaves the result open.
The government record has gaps as well. CBP described the information it lacks for direct payment. It did not say whether every submitted worksheet was retained in a normalized form, whether all tracking numbers passed format checks, or whether each package row can be tied cleanly to a Pay.gov payment. Monthly aggregate payments may require allocation work before CBP can certify a row-level principal amount.
Entitlement also remains a legal question. A tracking receipt can show who sent the package. A customer ledger can show who paid Zonos. Neither alone decides whether a merchant passed the tariff to a buyer, promised to return it, assigned the claim, or already issued a credit. A court order should define the presumption and the evidence that rebuts it.
Interest needs its own rule. For CAPE entries, CBP calculates interest as it does for other interest-eligible customs refunds under 19 CFR 24.36. A postal process would still need a stated principal, accrual period, rate, beneficiary, and custody rule. Principal can be matched to the worksheet after CBP reconciles the row to the monthly payment. Interest cannot be allocated reliably until the governing calculation method is stated.
The match also creates a data-minimization problem. Customer records may contain names, addresses, payment references, and cross-border transaction data. CBP needs only the fields required for the first match. The schema can use stable customer identifiers where possible and reserve personally identifying information for payment and exceptions.
If the mismatch rate is high, the result may split the population rather than defeat every claim. Clean matches could move in batches while missing, duplicate, or conflicting records go to a separate claims path.
A governing order naming the remitter as the sole beneficiary would foreclose this payer-based design, but the current public record contains no such rule. Even without that rule, contractual pass-throughs, assignments, and credits complicate any presumption that the sender owns the claim.
If CBP builds a postal channel with equivalent row-level checks, beneficiary controls, audit rights, and a timetable, a separate annex may be unnecessary. Permission to file would put Zonos's argument before the court but would not prove its data claims. Those claims still require a declaration, production protocol, or audited pilot.
What operators should preserve now
Qualified parties should freeze every version of the International Mail Duty Worksheet, Pay.gov confirmation, tracking event, and tariff calculation. They should separately retain the customer invoice, payment record, credit, contract term, and account identifier associated with each IEEPA collection. A normalized export is useful, but it should not replace the original record.
Carriers and postal operators should preserve the handoff between the postal tracking record and the qualified party. That handoff may explain a mismatch in sender identity, package count, arrival date, or customer account. It can also show whether more than one intermediary touched the same shipment.
Merchants and senders should retain the tracking receipt and the document that separately identifies the tariff amount. A total landed-cost invoice is weaker evidence if it does not distinguish duty from postage and service charges. Records of refunds, chargebacks, or buyer reimbursements should stay with the same package file.
CBP should preserve the worksheets in the form received and document any transformation into agency systems. If a worksheet was corrected, both versions and the reason for the correction matter. The agency should also preserve the relationship between the spreadsheet and the Pay.gov payment that satisfied it.
The next procedural window is already on the calendar. The court's July 2 order calls for another CAPE progress report on July 13 and a closed conference on July 14. A preservation direction and a limited data call could prevent record loss while the court considers whether and how to include postal shipments.
The court can test the ledger before deciding the whole remedy
Postal shipments sit outside the entry-based categories driving the broader refund fight. They have no conventional liquidation record, and an importer class would still leave senders without the ACE number CAPE demands.
A controlled sample can show whether CBP and selected qualified parties can build a reliable package-to-payer map. Subject to the court's remedial authority and the governing refund law, the court could ask CBP and participating parties to propose the fields, integrity controls, and reporting method. No payment would be needed during the test. The report should state the share of worksheet rows matched, the share of duty principal matched, the duplicate rate, the payer-to-beneficiary conflict rate, and the share requiring manual review. A single overall match rate would conceal the failure mode.
The sample would narrow the remedial choice. High match rates could support direct government payment, a supervised intermediary pass-through, or a hybrid, though each still needs a legal basis and beneficiary rule. The exception data would show whether unresolved rows fail because of CBP's worksheets, collector records, identity conflicts, payment allocation, or legal entitlement.
A sample would protect the public fisc without treating the missing ACE entry as dispositive, and it would protect senders without putting a lump sum in the remitter's hands. CBP has the worksheet. Qualified parties may have the payer ledger. The court should find out whether those records match before concluding that postal refunds cannot be administered.