IEEPA refund filing limits meet Canada's September 15 tariff changes
Separate surety-paid entries from the ordinary CAPE upload and check filing access and liquidation dates for the rest. For covered Canadian goods, reconcile product scope against both importation and consumption-entry or warehouse-withdrawal dates.
Yesterday's five analyses turn on specific filing and customs events: who paid an entry's duties, who can submit it, and which date governs Canadian goods. The ITC's separate consultation asks how firms can supply evidence safely.
Surety payments require a separate refund file. CBP's April 13 CAPE Phase 1 guidance tells importers and brokers to exclude an entire entry if a surety paid any IEEPA duties on it. Bond coverage alone does not trigger that instruction. The restriction concerns the submission route. It does not extinguish the importer's refund interest or settle treatment under future phases. Separately, 19 CFR 24.36(b) limits a qualifying surety's certified refund to its evidenced payment. Reconcile actual payments by entry and seek guidance from CBP and counsel on excluded entries.
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