Navigating Latest Tariff Developments

On February 20, 2026, the US Supreme Court held that the International Emergency Economic Powers Act (IEEPA) tariffs, i.e., the “Reciprocal Tariffs” and “Fentanyl-related Tariffs” are unlawful. Pursuant to further guidance issued by U.S. Customs and Border Protection (CBP), tariffs imposed under the IEEPA no longer apply to shipments entering the United States as of 12:00 a.m. EST on February 24, 2026. All other applicable duties, fees, and tariff programs remain in effect and are not impacted by the Court’s ruling.

Yes, the IEEPA tariffs will be refunded with interest in different phases. CBP has developed a system called CAPE (Consolidated Administration and Processing of Entries) within its Automated Commercial Environment (ACE) platform to receive and process applicable IEEPA refunds. They have advised that the system will be live as of April 20, 2026 to accept Phase 1 refund requests.

Phase 1 includes the following scope of entries:

• Formal entries (valued above $2500 or requiring other government agencies) with entry summary date (this is the day duties were paid to CBP) less than 394 days ago (Using April 20, 2026 as start date for CAPE this means entries from March 22, 2025 through February 24, 2026)
• Informal entries filed electronically (via ACE) with entry summary date less than 80 days ago(Starting with submissions on April 20, 2026 this would mean entries from January 30, 2026 through February 24, 2026)
  

Importers of record or their Customs Brokers are eligible to file for refunds via CAPE.

If DHL provided customs brokerage services, the customer can request DHL’s services to file the refund claim. To file, DHL will need either the list of eligible AWBs or the associated entry numbers. To file, DHL will need either the list of eligible AWBs or the associated entry numbers. Please email your DHL Account Representative for further steps on CAPE claim submission by DHL. DHL’s standard Import Paperwork Fee will apply.

Yes, if the IOR already has an ACE account, they can upload the applicable refund requests themselves in CAPE. CBP’s instructions on filing in CAPE can be found here. Should the IOR require a copy of their entries from DHL for purposes of filing the claim, DHL can provide electronic copies. An Import Documentation Fee will apply. Additionally, the IOR has the ability to access all entry-related data for separate or formally cleared shipments via MyUSEntry portal. To request access, email MYUSENTRY@dhl.com with your IRS#.

If you’re unsure if you acted as the IOR, the best ways to check are the following:

• Review your entry documents to see if on the Entry Summary form (Customs Form 7501) you are listed on box 26. If yes, you were the IOR.
• Ask your DHL representative to email our American Brokerage Services team with your IRS# and ask for confirmation as to whether or not you have a POA on file with us.
  

No, CBP has expressly stated that CAPE is the only mechanism to be used for requesting and for the processing of IEEPA refunds. Any PSCs submitted to request an IEEPA refund will be rejected. Protests already filed can be recalled to allow the shipments to be processed via CAPE.

Once DHL submits your claim request and it’s successfully uploaded to CAPE, CBP will return a claim #. DHL will provide you with this claim # and with an ACE account, you will be able to track the status in CAPE.

If self-filing, you will immediately have access to your claim number.
 

For Phase 1 entries, CBP has advised that they expect the full CAPE refund process to take 60-90 days from when a claim is accepted into the system.

• If DHL was the IOR, it is estimated that it will take another 30-90 days from DHL’s receipt of the refund to be able to reconcile and process payments to the customers who originally paid us for the duty at time of import.
• For customers who acted as IOR, they should expect to receive their refund into their ACE ACH account within 60-90 days from when their CAPE claim was accepted by CBP.
  

Where DHL was the IOR, checks will be issued to the party who originally paid the duty for US-based customers. For shipments that had duty and tax billed back to the shipper or a 3rd party, DHL US will credit those funds to the applicable country for distribution to the appropriate account holders.
If the customer is the IOR, regardless of who files the refund (i.e., if DHL files), the funds will be deposited via CBP into the IOR’s ACE ACH Refund account. CBP will not be issuing any checks for refunds. For information on how to set-up an ACE ACH Refund account or to verify that the account is already set-up, please visit the following CBP site: Electronic Refund Enrollment in CBP's ACE Portal.

If DHL was the IOR, DHL will file the refund claim and will not charge for this process.
If the customer is IOR and chooses to request DHL’s services as a Customs Broker to file on their behalf instead of self-filing, as part of the process, DHL will need to re-query and recreate your entry summary form. DHL’s standard Import Paperwork Fee will apply.

No. DHL will refund only those IEEPA tariffs that it receives back from CBP. Customs-related surcharges and fees are not subject to refund. These surcharges and fees are service-related fees that cover the operational, processing, and compliance activities performed by DHL at the time of import. Because they are not government-imposed duties—and because DHL does not receive any reimbursement for these charges—they cannot be refunded.

At this time, CBP has not released any information or timelines for when entries that are out of scope for Phase 1 will be eligible for IEEPA refund claim  submission. We are working closely with CBP to understand what the next phases will encompass and when we can expect them to be implemented.

Out of scope for Phase 1:

• Formal entries filed from February 4, 2025 (IEEPA start date) through March 21, 2025
• Informal entries filed from February 4, 2025 through January 29, 2026
• Any entries filed via paper entry summary and not filed via ACE, regardless of date of filing
• Reconciliation entries
• Temporary Import Bond entries
• Drawback entries
• ADD/CVD entries
• Entries with open Protest
  

Tariffs are taxes or duties imposed by a government on imported goods. They serve two main purposes:

1) Protecting domestic industries by making foreign goods more expensive, thereby helping local businesses compete more effectively

2) Generating government revenue, particularly in countries that rely heavily on trade. In the U.S., tariffs are paid to the Customs and Border Protection agency at ports of entry.

The amount varies based on factors such as the classification code, value, country of manufacture, and associated freight charges of the imported goods.
 

The responsibility for paying tariffs is determined by the shipment’s Incoterms® (International Commercial Terms), which are globally recognized trade standards. These terms specify who is responsible for transportation, cargo insurance, export and import formalities, duties, and taxes. They also define when the risk transfers from the seller to the buyer. The agreement between the shipper and recipient outlines who will pay the tariffs.

The impact of new tariffs will depend on your industry, the countries involved in your supply chain, and the specific goods you import or export. Tariffs may increase costs, requiring to reassess supply chains to maintain profitability and resilience. DHL can help you evaluate these impacts and develop strategies to adapt effectively.

DHL is your trusted advisor in navigating the complexities of recent tariff changes. Our tailored logistics solutions and extensive expertise enable us to support your business in adapting to these developments. Here's how we can assist:

• Comprehensive Logistics Support: From Express solutions to Freight Forwarding and warehousing, we offer a wide range of services to meet your needs.
• Global Expertise: With a vast logistics portfolio spanning multiple business units, DHL is uniquely positioned to transform challenges into opportunities, ensuring your business remains resilient and competitive.
   

DHL collaborates with regulatory bodies to anticipate policy changes and invests in manpower and technology to ensure efficient cross-border flows. We proactively gather, analyze, and share regulatory updates with colleagues and customers, enabling timely preparation and compliance.

With the removal of the de minimis exemption for Chinese-origin goods, all shipments - regardless of value - must now go through either informal (Type 11) or formal clearance (Type 01). This includes providing complete documentation (commercial invoice, packing list, HS codes, certificate of origin), potentially facing additional duties, and adhering to the latest U.S. import compliance rules.

In case of tariff changes after the exemption period, the customs entry date (typically the date of arrival in the U.S.) generally determines which tariff rate applies. However, regulatory updates may define alternate rules, so close monitoring of customs guidance is essential.

We are observing increased transit times and rerouting activity as shippers reassess their sourcing and shipping strategies. Some volume is shifting to alternative APAC countries. Ocean freight bookings from China are slightly down, while demand in Southeast Asia is picking up as customers diversify their supply chains.