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US Tariff Refund System is now live: What UK Exporters and Importers Need to Know.
Following his second inauguration as US President, Donald J Trump imposed significant Tariffs against certain Nations (Canada, China and Mexico), over the following weeks the rest of the world was affected, with the rates seemingly rising daily.
Opponents in the Senate argued Trump did not have the legal power to issue some of the Tariffs and a legal challenge began. In February 2026, the US Supreme Court found in favour of the plaintiffs and decreed that the Tariffs introduced under IEEPA (International Emergency Economic Powers Act) were outside of Trumps powers and deemed unconstitutional.
What happens next?
A new system, CAPE (Consolidated Administration and Processing of Entries) went live on Monday 20th April and will deal with repayment claims.
Refunds will only be made to Importers of Record with an existing US Customs and Border Protection (CBP) account and refunds (including interest) issued on a one-off consolidated basis, initially covering –
– Entries that are unliquidated (not finally closed by CBP)
– Entries liquidated within the past 80 days
– Certain suspended or extended entries.
There are no details yet on dates for re-claiming for the remaining imports.
While the system is aimed primarily at US importers, the move will have direct implications for UK businesses that export to, distribute within, or maintain subsidiaries in the United States, particularly those that acted as importers of record or paid duties through US customs brokers.
Many UK firms:
- Operate US subsidiaries that acted as importers of record
- Paid tariffs on UK or EU origin goods shipped into the US
- Absorbed tariff costs to protect US market share
Those companies may now be entitled to significant refunds, provided they act quickly and meet strict procedural requirements.
What UK Businesses Should Do Now: We recommend immediate preparation…
- Identify exposure – Confirm whether your UK entity or US subsidiary:
- Acted as importer of record
- Paid duties under IEEPA-based tariffs in 2025–26
- Coordinate with US brokers – Claims must be submitted via CBP’s ACE system, often by a licensed US customs broker.
- Prepare data/evidence. Refund requests use structured CSV files listing entry numbers and tariff amounts. Incorrect data can invalidate claims.
Strait of Hormuz – Why It Matters So Much…
The Strait of Hormuz is one of the most important shipping routes in the world with around 20% of global oil trade. Iran has largely closed the Strait since February 2026. The U.S. responded by blockading Iranian ports and attacking Iranian naval units trying to control the area.
As a result, many ships stopped using the route, global oil supplies were disrupted and energy prices rose worldwide. Oil markets remain unstable, with supply shortages tied to the disruption of shipping through the strait.
Current Situation…
1) Iran just made a new proposal to end fighting
- Iran has offered the U.S. a deal to reopen the Strait of Hormuz if the U.S. lifts its blockade.
- The proposal focuses on ending hostilities first and postponing nuclear issues until later.
- The U.S. has not yet agreed, and negotiations remain uncertain.
2) U.S. naval forces are still engaged
- U.S. forces have been authorised to target Iranian boats laying mines in the strait.
- Multiple aircraft carriers are deployed to the region — a sign of high military readiness.
3) The strait is still mostly closed
- Shipping traffic has dropped dramatically, with some estimates showing near-zero transit at times.
- Analysts believe clearing mines and reopening the route fully could take months.
Single Trade Window shelved?…
The STW has been shelved, according to the FT.
The UK’s planned Single Trade Window (STW), a digital platform designed to allow traders to submit all customs and regulatory documentation through a single entry point, has effectively stalled.
Freedom of Information disclosures reveal that no new funding has been allocated since January, no HMRC staff are currently assigned to the project, and delivery contracts have been closed. Originally proposed under the government’s 2020 Border Strategy, the programme has since been paused through 2025 to 2026.
While ministers maintain they remain committed to the concept, the lack of active development raises concerns. Industry experts continue to stress that a fully implemented STW would streamline border processes, reduce administrative burdens, and support end-to-end digitalisation of supply chains, making its delay a missed opportunity for UK trade efficiency.
The UK’s air cargo relies heavily on EU airports, with an estimated 40% never touching UK Runways…
Britain’s trade depends on Northern European airports than is realised. A predicted 40% of UK air cargo never touches a UK runway. Goods are often trucked to and from EU hubs such as Frankfurt, Paris, Amsterdam and Brussels.
This represents substantial, real demand for air freight services that is outsourced overseas. It remains largely invisible in UK airport planning, policy-making and public debate.
Structural Weakness in UK Freight
The UK currently lacks both the dedicated air cargo capacity and strategic planning levers required to handle its own demand. As a consequence, essential goods (food, pharmaceuticals etc) can be transported via EU airports.
This necessity adds in cost, transit time and emissions while weakening supply chain resilience. Disruption to the airfreight process, can affect availability of goods, inflation and public wellbeing.
Delays at borders, reductions in capacity at European hubs, such as planned slot constraints at Schiphol to meet environmental targets or geopolitical shocks, all pose direct treats to the UK economy and it’s security. Yet, the UK continues to rely on overseas infrastructure for cargo that originates from or is destined for, British businesses and consumers.
Road feeder services: normal practice, exceptional dependence
Road Feeder Services, cargo trucks operating under airline codes between airports, are a standard component of global air logistics. The unusual part, is the scale of the reliance in the UK.
Approx 1.7 million tonnes of cargo per year may be entering or leaving the UK by truck. Made up of RFS and cargo bumped from flights or routed via EU airports by non airline coded trucks due to capacity constraints.
EU airports are now critical to the UK national logistics system, despite any formal acknowledgement or plan to deal with the dependancy.
Trade, growth and border friction
Efficient air freight enables businesses to expand markets and operate globally. Without trade growth, the governments ability to fund infrastructure, public services and industry strategy is constrained.
Border friction since Brexit, has contributed to declining trade performance. As Rachel Reeves has noted in 2024, the UK ‘is too exposed to global disruption – but too closed to global trade.’ There is little evidence this has changed.
A critical data blind spot
The government cannot quantify the UK’s reliance on EU airports for airfreight. The post Brexit Computerised Transit System records every cross border movement, the system only allows one declaration to be viewed at a time, making meaningful analysis impossible.
This is a serious policy failure as without accurate data, effective planning cannot occur.
Key differences between EU and the UK
Germany plans cargo explicitly and nationally, rather than leaving capacity to market forces or passenger-led airport expansion.
The Netherlands measures and manages cargo dependency even when reducing capacity; the UK neither measure not mitigates it.
France aligns airport policy, industrial strategy and customs operations; the UK treats them largely as separate domains.
The US plans freight holistically and publishes data needed to manage risk.
Singapore assumes disruption will occur and plans capacity accordingly; the UK largely reacts after the fact.
Calls for strategic action
Accurate, accessible public data on UK airfreight flows
National planning for dedicated cargo capacity and contingency routing
Cross party political focus on supply-chain security
Structural engagement with industry on resilience, airport capacity and long term trade strategy
Without action, the UK risks discovering this vulnerability only when the system fails.
Article written by Sally Dixon FCILT
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