CAPE Phase 1 went live at the end of April 2026 and many U.S. businesses immediately moved forward with filing their entries to request a refund of the IEEPA tariffs paid throughout the past year. U.S. Customs and Border Protection began issuing these IEEPA refunds on May 11th and the impact on importer’s bond sufficiency was immediate. <\/p>\n
Prior to CAPE going live, the assumption was that the IEEPA refunds would be issued as the entries with tariffs paid liquidated. This would have made the impact on bond sufficiency a rolling update where an importer’s bond sufficiency percentage decreased gradually as these entries liquidated. <\/p>\n
However, what TRG has seen happen since CAPE went live has been different than what was expected. For the majority of importers, TRG has seen their bond sufficiency drop dramatically as the IEEPA refunds are approved and subsequently issued. This is due to the fact that as soon as the refunds are approved the tariffs are removed from the duties, taxes, and fees paid on all of the entries requested at once. Since the duties, taxes, and fees paid on entries within the past 365 days is how bond sufficiency is calculated<\/a>, the removal of the IEEPA tariffs from that calculation has a substantial impact.<\/p>\n So instead of seeing a slow, rolling decrease in bond sufficiency, TRG has seen a sharp and sudden decrease. There are exceptions to this situation that importers have encountered, so if this is not the case for your company, contact your bond providers to see if they can provide further insight.<\/p>\n In a new episode of TRG Talks Trade, TRG President, Travis Smith, discusses the early impact TRG has seen the IEEPA refunds are having on the current status of importer’s bond sufficiency.<\/p>\nTRG Discusses How the IEEPA Refunds Have Begun Impacting Bond Sufficiency<\/h2>\n