Video: Your IEEPA tariff refund checklist: a live Q&A with the National Retail Federation | Duration: 3404s | Summary: Your IEEPA tariff refund checklist: a live Q&A with the National Retail Federation | Chapters: Welcome and Introduction (4s), Speaker Introductions (157.54s), Trump's Tariff Actions (306.405s), Tariff Authority Shifts (461.95s), Tariff Implementation Challenges (629.81s), Tariff Refund Process (771.795s), Phase One Eligibility (922.78s), CAPE Filing Process (1118.885s), Founder's Tariff Strategy (1374.8s), Live Q&A Session (1701.98s), Partner Filing Requirements (1788.49s), Broker Import Process (1867.9s), Warehousing Duty Refunds (1922.93s), Liquidated vs Unliquidated (1980.62s), Vendor Tariff Charges (2043.785s), ACE Account Setup (2143.83s), Finding Tariff Rates (2219.12s), ACE Entry Status (2304.9s), Resources and Phase Two (2393.99s), Forwarder & Refund Issues (2483.28s), ACE Support Issues (2685.605s), Refunds and Accounts (2724.475s), Data Cross-Checks (2828.63s), Broker and Aggregator Questions (2926.06s), Q&A Technical Issues (3000.685s), Q&A Session (3091.6s), Q&A and Resources (3153.105s), Q&A Session (3259.3s), Questions & Contact (3295.63s), Resource Sharing (3315.255s), Session Wrap-Up (3361.245s)
Transcript for "Your IEEPA tariff refund checklist: a live Q&A with the National Retail Federation": Hello, everyone. Welcome to Saltbox and NRF's webinar on what ecommerce founders need to know about tariff refunds. Gonna be having a live q and a today with the National Retail Federation and a small business owner and former Saltbox member, who has experienced all of this firsthand. So I'm sure a lot of you are in the same position. You're dealing with suppliers and trying to figure out how to get your refunds. So make sure you write down all your questions. As we go along, we'll be doing a q and a at the end and answering anything and everything. So a little housekeeping for today. Here's our agenda. We're gonna be introducing our speakers very soon. As I mentioned, we have someone from NRF on and a small business owner. We're really excited to hear what they have to say. We'll be talking through what's actually changed with tariff refunds. There's been a lot going on in the news over over the past couple months, and things are changing pretty much daily to weekly at this point. So we'll kind of go through the latest and what you need to know now. We'll then walk you through the refund process, everything you need to know to get your refund submitted, as well as an operator's perspective. Like I mentioned, a small business is joining us today. So really excited to have them. And then at the end, we'll be doing our live q and a. So put your questions either in the chat, or there's a q and a tab if you want to make it easier on yourself. And then we'll share a resource at the end. I'm sure a lot of you saw when you registered. Anybody who attends today gets access to our free refund calculator. So you'll just update or upload your ACE data, and it'll essentially give you a, a number of what is expected to be returned to you. So keep that in mind throughout the session. You'll be getting that at the end. A few things, a few reminders, get to know each other. We love to to hear where you guys are from, your company name, where you're located. Feel free to drop anything about yourself in the chat at any time. We love to engage and hear from you all. As I mentioned, add those q and a's to the q and a tab. That's gonna be in the top right corner of your screen. You'll see the chat. There's a little tab that says q and a. That's where you'll drop them. And then lastly, everyone will be getting a recording, following the webinar. So you can rewatch this content at any time. Don't feel like you have to scribble down a bunch of notes. Everything will be recapped and available following the session. Alright. So let's get into it. I'm gonna go ahead and introduce our two speakers. We're gonna bring them onto the stage. So first, we have Jonathan Gold, who is the VP of supply chain and customs policy at the National Retail Federation, as well as Angela Hawkins, who is the founder and CEO and a former softbox member, from BanBlue. So I'll let you guys take it away. Great. Thanks, Monica. Appreciate the, opportunity to participate in today's webinar. Maybe just by a little bit way of background. So, again, my name is Jonathan Gold. I'm the the vice president for supply chain and customs policy with the National Retail Federation, been with NRF close to eighteen and a half years now, working on the government affairs side of the house on, trade related issues, supply chain, transportation, product safety issues, loss prevention issues, and a whole host of other issues as well. And tariffs has certainly been, one of the biggest issues over the past couple of years, especially the the past year. So happy to kinda lay out, kind of the framework, kinda where we are, how we got here, and kinda kinda what's happening with that. But maybe, Angela, if you wanna introduce yourself, and then I can get into the presentation. Absolutely. My name is Angela Hawkins. Many of you who know me from Bamboo know that I am a small business owner that focuses on, producing luxury bedding and pajama products made of bamboo. Over the last few years, though, I've been quite active in the advocacy space. I've been working with the NRF, going to Washington DC to advocate for small businesses, basically given a voice to what we're experiencing out here on the streets to make sure that they know that real people are behind the decisions that they're making. I'm also a very, active still an active member of the Saltbox, but if I'm a different perspective, I actually bring a lot of the advocacy to, to the the Saltbox. I wanna make sure that they understand what it is that I'm doing and what it is that I'm seeing. And I also wanna give them an opportunity to come to the table and, if they wanna participate as well. So, that's what I've been doing. I I I love being able to be the voice, and I love being able to get people to come in and and actually use their voices as well because the decisions that are being made truly do impact small businesses, and the best way for us to let them know that we're impacted is to speak up. So happy to be here. Yeah. Let me just thank Angela for her her advocacy and her efforts and her engagement. It's it's been wonderful having her and other small businesses engage with NRF and do our our hill visits, advocacy efforts, videos, what have you. It is so important for members of congress and other elected officials, press, and just general public to understand from businesses what tariffs are, what they mean, how they impact you, how they impact consumer, and the economy as a whole. So it's been a pleasure working with Angela, you know, over the the past. year plus on these issues. So, why don't we go ahead and jump right into it here? Okay. So, you know, we've talked a lot about tariffs, you know, for for quite a while, even, you know, going back to the first Trump administration. But, certainly, there's been a lot of activity over the the past year plus now since president Trump has, you know, been in office for a second term. You know, the president talked a lot on the campaign trail, about tariffs. He talked about, you know, putting in place a 10 to 20% baseline tariff, potentially a 100% tariff on China. He talked about specific industries he was looking at, and we certainly expected on, you know, day one last year that he was gonna put tariffs into place immediately. That didn't happen. He put in place the the America First trade policy memo, which outlined a whole range of studies that they wanted to do from different agencies, looking at trade and paving a way to get to tariffs. That all kinda got, you know, pushed inside as the president started rolling out tariffs right away. You know, there are a variety of different authorities that we expected the president to utilize, some that had never been utilized before for tariffs, but, you know, this is something that he was was pushing forwards on. The, the International Emergency Economic Powers Act, IEPAA, you know, that's where we got the the the baseline tariffs. It started with Mexico and Canada and China for, immigration related issues and fentanyl related issues. It went from there to, the liberation day tariffs on on April 2. After that, it seemed, you know, every time the president was threatening a tariff action, it was under AIPA. We had additional tariffs on Brazil, additional tariffs on India, and the president has continued to kinda roll out these IEPRA related tariffs. The court supreme court has struck down the IEPRA tariffs. It they knocked down all the tariffs that have been put in place. So that was the the kind of Mexico China tariffs. That was the, the liberation day tariffs, the universal tariffs. It was also the Brazil and India tariffs. Unfortunately, they pivoted right away after the Supreme Court ruled to what is known as the section one twenty two tariffs. This is focused on balance of payments issues. I think many would argue we don't currently have a balance of payments issue. We might have some trade deficits, but we certainly don't have a balance of trade or balance of payments issue. But with the court, striking down the APA tariffs within, I think, was five hours, the president signed an executive order to place a 10% global tariff, under section one twenty two on all countries. The next day, the president said he was gonna raise that to 15%, but we haven't seen that increase as of yet. And section one twenty two allows a max of 15%, but it's only in place for a hundred and fifty days. So that tariff is gonna expire on July 24. Congress does have the opportunity to vote to extend the section one twenty two tariffs, but at this point, we certainly don't expect congress to vote in favor of any tariffs, especially right before a midterm election. So, we just don't think the votes are there. But with that being said, the administration has also pivoted using other tariff authorities. He's talked about section three zero one. He utilized section three zero one during the first administration with the tariffs that were put on China. And section three zero one tariffs are really focused on, country specific related issues, but they've launched two different, investigations, one on forced labor and one on structural excess capacity. The forced labor investigation focuses on 60 different nations. The excess capacity focuses on six. And as much as ambassador, US trade representative Greer has said they're not gonna prejudge the outcome of any of these investigations, they're moving them very quickly. You had thirty days to, provide commentary on the notices, and they're following up with the hearings starting this week on, forced labor and next week on the excess capacity. And then they're gonna move quickly to what is typically the second stage where they will then identify what remedies they're gonna put in place, which could be the tariffs, and then list a whole host of HTS numbers that could be subject to tariffs potentially at different levels from different countries that the public will have an opportunity to weigh in on, and, hopefully, they will have another hearing for companies to and associations to talk about the impact of those tariffs. But we have these two investigations now. USTRs talk about other potential investigations as well, that could, you know, put additional tariffs in place as well. And then beyond the three o ones, we have what are known as the section two thirty two tariffs, and these are on product specific categories. And we've had a host of, two thirty twos have been announced, that are going to, to continue, and I realized I haven't been advancing my slides on what we're doing. So this gives you a better idea kinda where where things are. So I've got into that. I've got into that. So all the two thirty two tariffs are in place. Certainly, I'm sure folks have heard a lot about steel, aluminum, and copper, but there are a wide variety of different, sectors that we've had tariffs put on. Autos, we've had tariffs put on. One of the ones two of the ones that we're most concerned about right now are, semiconductors, which could be in a wide variety of products, everything from consumer products to, you know, high functioning machinery. It depends on how broad the scope is gonna be for what the administration wants to do. Robotics is another one that we're very concerned about, especially for warehouse operations where a lot of this is going automated right now. So lots of concern about how, these two thirty two tariffs are are implemented, concerned about how they stack on top of one another as well with the three zero one tariffs and, potentially one twenty two tariffs. The other concern too is just the speed at which they're announcing these tariff actions and how quickly they're taking effect, especially on things like the two thirty twos where they make the announcement and then they go into effect a couple of days later. We witnessed that recently with the change they made to the steel, aluminum, and copper tariffs. They were announced late on a Thursday night and then went into effect at 12:01AM that following Monday morning over Easter weekend. So you had folks who were scrambling trying to figure out how this works because you gotta figure out what the level what the content level is in products. Is it wholly made of steel, aluminum, and copper? Is there a percentage of steel, aluminum, and copper in that? How do you figure that out to figure out what the potential tariff rate is gonna be? You know, they had also provided, with some of these tariffs a what they call an on the water provision where you can have an, you know, an extension or an exemption before the tariffs actually take effect for any product that's put on a water, say, thirty days before the announcement, but they didn't put that in place for these, recent February. So, again, companies are scrambling trying to figure out you know, you've got product coming in in the next day or so that you thought it was one tariff rate, and now it's gonna be a different tariff rate. I think as you all know, that tariff has to be paid when the product arrives, you know, within fifteen days. You can't wait months before the product gets on the store shelf to sell it to then pay back the tariff. It's gotta be paid immediately, which has been another, challenge we've been trying to educate folks about. So with the Supreme Court, you know, knocking down the IEPAA tariffs, there was lots of discussion about refunds and what was gonna happen with the refunds. During the Supreme Court argument itself, there really wasn't a whole lot of discussion about the refunds, just because that wasn't part of the the argument. There was one question that came up during the, during the the arguments where one of the, justices asked about the tariff refund process and and how that would work. The the lawyer for the plaintiff said it could could be a mess. To be honest, I wish she hadn't had said that because it didn't need to be a mess. You know, the the refund process is something that customs does all the time. They have a refund process they do for other issues outside of, you know, what's been going on with with AIPA. But with that being said, as the, the the court the case was pushed back down to the Court of International Trade who had jurisdiction on the refunds, the CIT then began working with customs on that whole refund process. From the outset, customs says they couldn't do the refunds immediately. They were gonna need time to get the system in place. So they said they needed forty five days, and that was beginning in February. And they had provided updates on a weekly, biweekly basis with the the court, and they actually made progress. They they got to the starting point of the refunds, beginning on April 20. They launched what is known as the consolidated administration and processing of entries, cape, which is a, system within the automated commercial environment, ACE, which is the main customs processing, program. So they've utilized that, and they are you know, made some requirements for in order for you to, file for a refund. First and foremost, you must be the importer of record or the authorized custom broker who filed the entry. You must have an ACE account, and you must have your ACH, account as well because customs is only doing electronic refunds now. They've stepped away from doing paper checks. It's a much easier process for customs. I think the much easier process for businesses as well. I know in talking with with companies previous to this, as we looked at other trade programs that expired that were retroactively renewed and they got, you know, refunds back, they were getting stacks and stacks and stacks of checks, you know, based upon each entry. This way, it's more of a streamlined process for for everybody. So, you know, customers did put some some, parameters in place for eligibility for the phase one. They're doing this in a a bit of a phased process. They think that for the $166,000,000,000 that, you know, overall will be refunded, about a $127,000,000,000 worth of, tariffs will be refunded through the phase one, process that they have, put in place. So, you know, they've limited this to, unliquidated entries or, entries that are eighty days past your liquidation date as a starting point. They will accept, but not necessarily merely process, refund or liquidate those with a liquidation status of suspended, extended, or under review, or a warehouse or a warehouse withdrawal. And then phase one will not process or accept entries for which there is a final liquidation. Those have been flagged for reconciliation, those on a drawback claim, those covered by an open protest, those that are not filed, in ACE with or without liquidation status in ACE, and then those that are subject to, an antidumping countervailing duty order for which Commerce has issued liquidation measure liquidation instructions that are pending. You know, they've they've said they wanted to try and get the the easier entries done first, and some of those that in the later stages are a little bit more difficult for them to to kinda go through. So, you know, there's a lot of discussion, early on about who would be able to get refunds. Is it just those that have filed a court case? Those are subject to the and the court came back and said no. These tariffs were collected legally from everybody. Therefore, everybody is due a refund. So I know a lot of companies are struggling with, you know, do I file a a case of the CIT? Do I do a protest? I think it really is up to each company. And let me just, you know, say, I am not providing legal advice to anybody. Please make sure you're talking to your your your attorneys, your customs related folks, and and your brokers to kinda really go through everything. I'm just trying to provide some oversight and kinda let me know kinda where where things are. But please don't take anything I say as legal legal advice. So let me just, I should have said that at the start. But, with that, you know, we've heard a a a different opinions of how everything went last week on on day one. Obviously, everybody was very eager to, get their refunds. So, obviously, you had a flood of, requests beginning at 8AM when the when the system first opened. I heard from members who said they had no issues with getting their declarations uploaded while others ran into issues with with ACE overall and, you know, spent six hours on the phone with ACE, customer service. So it it was a wide range, but I think for the most part, customs feels pretty good about what they were able to do last week. I think they said they had 55,000, unique, entries, on the system, so certainly is a a positive for customs that they had, such good effort at the at the start here. Sorry. We're doing a poll right now. But I think, you know, for the most part, customers has made it pretty pretty easy for what you need to do, at least for the initial declaration of, you know, looking for a, for your refund. Really, all you need to do is file your entry number and upload that in the declaration in the cape system. That's all they're looking for in a CSV file. And then, initially, customs will kinda go through that and make a determination, if it's the right entry, if there are any issues with the entry, if you put in duplicates or anything like that. And then they'll they'll give you an opportunity to correct the, any errors and move quickly to be able to to do that. So, again, I've heard mixed reactions. I think most folks were able to get get some of the issues addressed. But that first step is, again, updating or uploading your, your information, just the entry number. I think there was a lot of concern early on about what you're gonna need to, you know, from the outset to prove, you know, the entry, but would certainly encourage everybody. Make sure you're you you have all your ducks in a row from the outset. You know, before you even decide to file your your entry numbers, you know, make sure you're determining the eligibility, looking at your entries to figure out, you know, whether or not they qualify for phase one or they deemed, you know, one of those more complicated entries that are deemed for, kind of a later later phase. Make sure you've got all your documentation. Make sure you can prove everything within your entry. You have all your financials. You have to make sure that the h t HTS numbers are correct. Make sure your rule of origin, is is correct as well. Customs is really focusing in on enforcement on a wide variety of issues looking for for fraud. And while some of these errors might be innocent, you know, they're gonna gonna go after some of those. So you gotta make sure everything is correct, for kinda later stages in the the CAPE process. And then you have to file through through ACE. You've gotta go into the ACE and then go to the cape portal to file either you or your your broker who you've designated to be able to do that, and then you can continue to to track your claims as they go through. Now, you know, there are a series of steps that happen once you upload your your, cape submission, the declaration. That should happen very quickly. You'll get accepted or or not, but then once you move off of there, then customs looks at the the processing of the the claim. So as a part of that, they will certainly review the the entry. They'll take out the duties. They'll do a new entry and, and the refund calculation. So they'll determine how much is gonna come out or not. After that processing, they'll then move to the review and liquidation. And during that review process is when they're really gonna take a look at the entry to make sure all the information is correct. Do you potentially owe money somewhere else for a $2.32 tariff or some other action that could be taken against you? At that point, you know, they could decide to hold back some of the AIPA tariff refund to pay for what other other issue is there. That's kinda what they're calling the offset. If you do owe money somewhere else, they'll utilize that, AIPA money to to pay for that. So something just to to be aware of. And then, you know, hopefully, within sixty to ninety days total, you can look to get your your tariff refund. That review process, they say, is gonna take about forty five days, but the process, entirely should take about sixty to ninety days, unless you run into some some significant issues with the, with the entry. But, again, you know, make sure you're working with your customs broker to have all that information, accurate. I've talked to many brokers who say there's a lot of bad information in some of these entries, so you really gotta spend some time to make sure that your entries are, clean and updated and correct before you, go through this this process. So let me stop there, and I'm happy to take questions afterwards, but let me go ahead and, turn to Angela for the operator's perspective. Hi. Thank you, John. I appreciate that. I wanted to jump in here just a little bit and just give you a perspective from a founder. And it's not a traditional. I don't have a traditional setup, so I'm not actually applying for the refund because I used what was called DDP shipping. Some of you may or may not know what that is, but it's it's defined as delivery, duty paid. So my supplier actually covered the tariffs, the duties, and the delivery all the way to my door. And the reason why I chose to do it that way instead of the traditional, where they relinquished, responsibility at their port was because of the fact that I needed that certainty. When it arrived, I needed to know how much was gonna cost. It was mentioned earlier that the, the tariffs were coming in hard and fast when we started seeing them from the day of, Liberation Day. We heard what those tariffs would be. We saw them changing overnight flipping and flopping from one percentage to another, and it was clear that there was no certainty, no ability to really, decide what or, project what that total price was gonna be for me once it hit the dock. And the danger in that is that I've already paid for the the products. I've already paid the supplier for everything. So if it arrived at the dock and the the tariff was more than I could afford or was way beyond what I thought, was gonna be or what I knew what I could afford. I was gonna lose my products. So the best thing for me to do at that point was to, utilize the DDP. But that also meant that it took away the opportunity for me to apply for a refund. My supplier is due to refund as opposed to me. But, again, like I said, it gave me the certainty, when I actually placed the orders to know what I was gonna pay, before it actually arrived. But there was a lot of things going on at the time when these, tariffs came down, and it changed my business significantly. I think, I was in a unique position because I was actually in DC. I was, doing one of what we call the fly in for NRF when the liberation date actually happened. So I I got an opportunity to see not only how it was gonna impact my business, but I saw how it was gonna impact a lot of businesses. There were hundreds of businesses in the room when those percentages came down, and it was an emotional, I wouldn't call it a roller coaster. It was an emotional train wreck. Most people in the room knew exactly what those tariffs were gonna do to their business, and they knew that it wasn't a good thing. I saw a lot of people picking up the phone and calling their suppliers. I saw people putting their, orders on hold. I actually saw some people physically shaken and, and upset at what these tariffs were gonna do to their business. And then eleven months later, exactly what we thought was gonna happen happen, which was that they were ruled to be illegal, but we were already impacted by the change for eleven months. For me, I stopped ordering at the level that my business needed me to order, which meant that I had to sacrifice revenue and growth in order to ensure that I, could afford the products that I put on my shelf. That also meant that my inventory was down significantly lower than what it should have been, but it was a decision that I made again because the price to, to get those those shipments in was just a bit more than what I could afford to do and not pass that on to my customers. I know that there were a lot of businesses that did decide to pass that that, cost onto their customers, but there were some industries like in my business, it's luxury bedding and pajamas, where in in times like these, luxury products are really not what you want to adjust in order to meet, you know, a change like this because part the customers are already telling you that they are changing their buying habits, and they're focused on the necessities. They're trying to decide if they can pay for food or medicine or rent, and so a luxury product really can't bear the, the additional cost. So I chose to absorb that cost. And because I did a DDP, I was able to better understand what that was gonna look like in the long run, which also meant that I made some, significant reductions to my inventory to do it. So now we're looking at what is it you know, what does tomorrow bring? Do we continue to do the DDP, or do we con or do we wait to see what happens next? I think the biggest thing that scared me was when I started to say, okay. Section one twenty two hit as soon as the the IEPA tariffs went down. So it was just like, okay. There's too there's still, too much flexibility. There's too much fluidity in these tariffs, and these tariffs directly impact my business. I knew that from the time that I started the business. That has always been on my, my risk and, my risk and analysis schedule, but I never thought that they would move this fast, and I never thought that they were cut this deep. So at this point now, the idea is just to keep in lockstep with my supplier and ensure that they are, doing the best that they can in terms of the DDP pricing that they offer me and, me doing the best that I can in in order to, maintain a, productive relationship with them as I, continue to grow my business. Okay. I think that's it. And I will, turn this back over to Monica. Thank you. Thank you, Angela and John. Great perspectives. I think that, John, you bring a lot to the table from, a re resource perspective, just kind of setting the stage for what needs to happen, what folks need to file. And, Angela, I love that you kind of talk through your experience as a small business, especially with DDP and how you saw what was happening and you jumped on it and said, I'm gonna make sure that my customers are impacted by this. I think that's something to be celebrated, and I think a lot of times, a lot of businesses might not know if that's the right choice or not for them. So great to have the different perspectives, and happy to hear that it ended up being okay in the interim at least for a while for you. But now we're gonna open up for live q and a. I've seen a couple questions come in throughout the session, but also, some of you might have seen we did have a pre q and a form submission that you could have made when you registered for the event. So we'll also be sharing those. But, yeah, if you have any questions, go ahead and drop them in that q and a tab or the chat. We can always push them to the q and a for you. So it looks like the first question comes from VG, and it says, if my manufacturing partner is the importer of record and collected my money to cover the IEPA tariff for a piece of equipment I purchased, can I still follow the refund process? John, I think this might be a question for. you. You're you're gonna have to work with your manufacturing partner to do that because they're gonna be the one that has the access to the ACE account and can file that information, and track that. So, unfortunately, that's something where, again, you have to work with your your your partner and figure out where they are in the process. You know, this is one of the questions that continues to come up if, you know, you're not the importer of record. You know, you purchased from somebody else who imported the product and they pass along cost to you. This is certainly something where you're gonna have to work with your partner. Hopefully, you've got some contract language that you can deal with those those pass throughs, and and have those ongoing conversations. But this is, again, where, you know, you gotta consult with some some legal expertise on how to address some of that. But, you know, this is just one of those challenges that we're facing right now because we know those costs are passed along. But if you're not the actual importer of record or the broker, you can't file, as part of that. But, hopefully, you know you know, many small businesses are facing this issue. You just encourage everybody to work with your partners and figure out, you know, how you wanna make sure they're filing for refunds, you know, first and foremost. And then, you know, obviously, it's gonna be a contract a contractual issue you're gonna have to kinda work through to see if there are some savings onto the line that you can get. Great question. Awesome. Next question we have is from Laura, and they asked, how do I understand if DHL slash UPS are the importer of record or my business? It's not made clear on the import documents that I have. If they are managing the import process for you, if they're filing the entries, then they certainly would be the the broker. We certainly encourage you to talk to DHL and UPS. You know, they made public statements about refunding money to their customers. You know, they certainly work in a different space because they are acting as a as a broker. So they've got records knowing who's imported, who they've imported for, what the tariff rates were. I know there are questions about the fees that UPS and DHL and FedEx were all charging. Unfortunately, that's not part of the refund process. That's, again, another conversation I think you need to have with those companies, about how to address some of that. Alright. Next question we have from Kanisha. Apologies if I mispronounced that name. And they're asking, my client ships items, to my company for us to distribute slash ship within The US for their behalf. We are not purchasing from them, just warehousing and shipping, but we have had to pay duties, billed to us from DHL and FedEx. Do we qualify to request a refund? I think this question is similar to the last one, but, John, I'll let you weigh in. Yeah. Again, there, I would go back to DHL and FedEx, because if you're warehousing, it's a kind of a different bit of a situation, and, you know, warehousing is not eligible at this point for a refund. But, certainly, talk to DHL and FedEx and figure out how best to, how to address that and whether or not you got you qualify, under what's what's currently required for CBP. Thank you. Another question is, can you define liquidated versus. unliquidated? Great question. Yeah. So liquidated, typically means that customs is is finished with the entry. Typically, liquidation is about a three hundred and fourteen day process where customs will go through and ensure everything is correct and accurate with the the entry. Everything's paid correctly. Everything's classified correctly. At that point, they they deem the entry okay, and they essentially close the entry. So it's liquidated. The concern had been that customs was kinda speeding up the liquidation process, because there are questions about whether or not liquidated entries would be eligible for tariff refunds. The judge, you know, judge at CIT said, yes. They are. And so customs is gonna have to figure out now a process. How do we kinda reliquidate, reopen those entries to kinda figure out that that process? So that'll be, hopefully, phase two, of the the cape process. Awesome. That was a great question. Next question is from Carolyn. And this one is for you, Angela. It says, Angela, thank you for your story. It's almost identical to mine. My vendors are charging me 15% tariff, and they have already told me they will not be refunding anything because they didn't pass on the total tariff charge they paid. Is there anything as a small business I can do? I think I'm gonna refer back to John on this one, because it I mean, they're clearly identifying the 15% tariff on your bill. So it seemed to me that it would be eligible, but I'll let John speak to Yeah. it. I would also be curious as to what 15% they're charging you. I mean, there's a wide variety of different tariffs in place right now. If this is the section one twenty two tariffs, those are only 10%. They're not 15%. So I I would go back to your your vendor and ask them exactly what tariff they're charging you with 15%. But, again, here, this is where, you know, having conversations and what's in the contract and how do you get some of the money back is is you know, again, talk to legal counsel about that. Yeah. It looks like Carolyn was saying, they were trying to tariffs, if that gives any different response to what you said. So those are the section three those were the section three zero one tariffs from the first administration. But, again, there, we've got that section three zero one tariffs at 15%. They're the one twenty two tariffs at 10%. And then depending upon the product, you know, whether it's subject to the two thirty twos or not. So, yeah, just make sure you understand which tariffs are being applied at this point in time. Awesome. Next question is from Haley, and they're asking, where do we find the declaration form? We submitted the entry number, but wasn't sure if the declaration is the same. Sure. So when you log in to your ACE account, there's gonna be a cape tab. When you open up that tab, there's the declaration form, which is essentially a a CSV file, that you put your your entry number in and you upload it. And then there should be, you should be able to track it through that cape tab, whether it's been accepted or not. Next question is from Greg. How do you obtain an ACE account? Great question. great information up on the CBP website on how to go about and do a, an ACE account. If you take a look at the, shared the, the resource from CBP on on the IUPE tariffs, it should be within there as well. But if you just go log on to the CBP website and and look for ACE account, they'll provide you the the tutorial on how to, get an ACE account. But then again, on top of that, you've gotta do the ACH, part of that as well with your US Bank account. Greg, I just, repost the link that John shared in the chat, so you can check that out. Hopefully, that answers your question. Next question we have is from Paul. How do you find existing tariff rates for products imported from China in the next couple of months to be imported? That's a good question. I wish I knew what the tariff rates were gonna be telling me. I I Therein lies the problem. yeah. No. But, I mean, look, in all seriousness, you know, customs has an information up on their website. If you go to the the ITC and look up the HTS codes, for your product specifically, they'll have those those codes. But it's, you know, you can check the the White House as well, the website. They've got up there the declarations, on the different products. It just it depends upon what your product is and what the tariff rate is gonna be. And, again, we're still trying to figure out what's coming, you know, with the three o ones, when the 01/22 tariffs come off in July, kinda what's next. So there's you know, continue to work with your brokers. They can tell you exactly what the tariff rates are as well. There are lots of different resources out there you can use. I mean, it's able to, you know, chat GBT, your product, and tariff code, and it should come back with some responses for you too. But check those with your broker too. Make sure you check your broker. Do not consult TRAT GBT for legal advice, Correct. That is correct. but it is a great resource to find information you're looking for, get questions answered. So. definitely check that out. Always double check it though. Yes. Always double check. Mark is asking, John, one of our entries was uploaded and received a statement processing not complete. This was an early April shipment arrival, and duties have been paid by us to our broker and our broker to US Customs. Do you know what the typical timing is before the shipment is complete and ACE shows it as accepted? You know, again, it's gonna vary product by product, entry by entry. There could be an issue with the entry. Some some information is missing. I but if you already paid, you paid the duties to the broker, I I would check with the broker, see what the problem is. They should be contacting CBP, and the ACE accounts to figure out what's going on there. Great question. And we have another question coming through. Greg is asking, what is a CAPE submission? Yeah. So the cape submission is basically a a CSV form with it's one column with all your entry numbers, and they're, the submission will take up to 9,999 lines, per submission. And, again, once you log in to your ACE account and you go to the cape tab, it's right there. You just download it, put in all your entry numbers. I think they say you can either use a dash or not use a dash, and they'll go through and be able to figure out, make sure Lots of great. questions. Kenisha has another question. I need a more basic understanding of all of this. Where can I go to level up and ask better questions? I think starting with the CBP website, they've got a lot of, good FAQs that are up there, on from the basics to some of the more complex issues. We continue to submit questions to CBP based upon feedback from our members. We certainly hope they're utilizing those for additional FAQs. CBP will also be hosting a number of different webinars. They've got a a slide deck up there from ones they were doing last week. They're having another one they did one last week, another one this week. They should be up there, relatively soon as well. Haley has another question. Do you think phase two is likely to occur in the near future? I I certainly hope so. I think, you know, within the next couple of months at at the at the the max, hopefully, you know, as things progress and they're you know, see the success with phase one and identify what some of those more complex issues are to be able to go through. They can start working on phase two. I know the the judge is gonna continue to ask them. I think they've got the next scheduled, check-in with the judge on, tomorrow, I believe, twenty eighth. So we should hopefully have some information coming out of customs, there. Hopefully, the judge will continue to ask about phase two. I think it's an important issue that she needs to that he needs to continue to ask. Next question is from Mary. If I use a forwarder, will they be the importer of record? That's an interesting question and a really good question. Yeah. I I would encourage you to call them and ask them and see if they are the importer record. I don't necessarily know that they would be, but I would check. Yeah. From If they're collecting, only the DDP, go ahead. yeah. In my case, with the DDP, they do refer to themselves or the business the company that they use as the forwarder. So they are the importer of record. And one other thing I wanted to just touch, touch on. John had mentioned, that when someone said that they paid 15% and they weren't gonna be able to get a refund, when you check the date of your of your your import and then check that against what was in place at the time. Because as John mentioned, there are some other tariffs that are in place that may be that may include or be up to that 15% that did not include IEPAA. So if that's the case, then then that would probably why they wouldn't give you a refund. But if you're if you're, total tariff that you're paying is in excess of the base tariffs that were already in place before IEPAA, then, I would say that you have a case to, kinda push back on them to get a refund. Yeah. Angela, that's a good point because that 15%, if that was the, you know, section three zero one tariffs from the the first administration, those aren't subject to the lawsuit and and the refunds. Neither are the, you know, any two thirty two tariffs or the three zero one tariffs. It's really just those AIPA tariffs that were put in place, you know, Liberation Day and and beforehand. And those kept going up and down. So you may figure out what the the rate was for each time. Jan is asking, once we get our ACE account set up, will the keep system have a record of what tariffs are eligible to us as the importer of record? Only if you file within your, within Cape. You've gotta go back you've gotta go through and upload your entries, and they'll figure out what the the tariffs are, what the AIPA tariffs were. Great question. Next, we have James. He's saying, I thought my EIN would be my, IOR number, but that format is not the correct format. Where else can I find that? If you're in ACE, you can log in to the ACE account and get your I o IOR number or call, again, call custom support to to help you out with that. These are all really great questions. This is a bit of a long one, but from Rocky, what about tariffs from India? We were charged nearly 50% many times. We were told. that we are IOR, but there aren't numbers making it clear. We're not able to get online with ACE either. The site keeps sending a one time password via email and then saying there is no account even though we registered. Yes. The India tariffs India IEPO tariffs at 50% are eligible for a refund. Again, I would encourage you to contact a support, to figure out what's going on and why you can't log in to the to the system. That's the only place you're gonna be able to go to get that that issue resolved. But that India 50% tariff, the AIPA tariff is eligible for a refund. Good. And, obviously, I know the I know ACE support is extremely busy these these days, so just have some patience working with them, either email or or try to call. Again, I noted I had one member who spent six hours on the call waiting on support last week waiting. So, Wow. yeah. I'm hoping it's not as bad this week, but, you know, that's that's the only way you really get that that issue resolved. Six hours. That's a long time. Yeah. Yes. Well, it's an important issue. Make sure they can. get into the system. I would wait six hours too. Yep. Another question from VG. The section 12210% tariff is not registered. due to liberation date, is it? Correct. No. They were they were effective. The, whatever the date they were put in place was, February 20 or something like that. So from that day, a hundred fifty days. So they they expire on July 24, again, unless, congress decides to renew, which, again, I don't think they're going to do. And the president just can't do it again. He's got a one one time shot at this, so they will expire in, in late July. Another question from Sassy. If I paid the tariff to UPS, then should I contact rate? Yes. Correct. When in doubt, contact the folks. At UPS and Fax and DHL. Next, we have Carla. Can I assign any other company bank account to be eligible for my refund as we do not have a bank account in The United States? I I don't believe you can. You have to have a US bank account. That's a great question. Next question coming in a moment. Bear with us. We have a lot of q and a's coming through. We're just trying to sift through. Mary is asking if I use a forwarder, will they be the importer of record, and is there a deadline to apply for an ACE account? There there's no deadline to apply. Again, I would go back to the forwarder to make sure that if they are the importer of record or not and identify who the right party is. But there's no deadline to apply for Ace, but, certainly, would encourage folks to do it sooner rather than later. Next question is from Jan. I get that once we uploaded our data, they will be able to tell us if I'm if it's available for a refund. My question is a little different. I heard chatter that they would have their own records showing what we paid as IOR that we could use as a cross check against our own records. Do you know if that is correct? Yeah. I mean, that's all the that's all the data you upload in in in the ACE system, ACE in in the ABI. So certainly encourage you and your broker to go back through the entries and identify what the tariffs are and, you know, check that once you see the process moving through and they see what you're eligible for, to make sure it's accurate. But all that date all that data is in ACE anyway. You should be pulling that data out of your ACE account to figure it out. Awesome. Thank you. Baruch, we have, are you expecting the government to be aggressive with other dependencies against the business or people that fit for it? I I certainly hope not. They certainly shouldn't be. I know the president has certainly made some comments about about refunds, but, look, the the these are money that was taken illegally from US businesses. You have every right to go back and ask for those refunds, and utilize them however you see fit. But I you know, the president hasn't taken any action thus far against any company that's spoken out or has filed a court case. So, you know, certainly don't don't think that's the the case. But, again, encourage folks to, you know, have those conversations internally and, you know, talk to counsel about, you know, all the different contingencies and and issues that are out there. That's a good point. We have an anonymous question. They're asking, my customs broker already found our entry and started the filing. He says I don't need to do anything. Do you think I'll actually have to do something such as provide banking details? Well, your banking details should already be there within within ACH. So that's that account should be set up. I wouldn't just sit back and rest on your laurels. I would certainly be talking with your broker and make sure all your information is accurate and correct, and that should be done before the, CAPE submission is made. This way you don't run into any issues, as the system starts processing. Another anonymous question. We ship via UPS standard through an aggregator, which is ClickShip. Our duties are buried in consolidated entries, and we don't have individual seven five zero one entry summaries. Does the NRF have any information on how these aggregators will provide the specific IEPA duty breakdown for the new CAPE portal? Mhmm. Unfortunately, I do not. This is, again, another one where I would encourage you to go back to UPS and have that conversation to figure it out figure out what they're gonna do and how they're gonna be able to disperse the refund that's owed to you. Awesome. And I think some of these questions are now from the presubmitted questions. So, hopefully, I know we had somebody in the chat. Jim asking about the presubmitted questions. So all of the ones you see now are from those submissions. They're coming in as anonymous, so just keep that in mind. If we do forget your question, please please please put it in the q and a, and we will get to it. So now we have, if we're getting the goods value amount not allowed on IAEA HTS line, Do we need to make a PSC to remove the value from IAEA lines? I would go back and talk to your broker about that entry that may be one that just doesn't qualify in phase one. So it's trying to figure out exactly what the issue is, and whether or not they recommend you do a a PSC. But I would certainly talk to your your broker or trade counsel to to figure that out. K. Another question from Maya. My import record was on July 2025. It is not belonging to the first phase. I already registered to the system. What should I do? Hold tight until phase two comes out. Hopefully, those entries will be, available under phase two. When in doubt, phase two. Yeah. I'm and I'm hoping there are only two phases. I I really. you know, I'm hoping it doesn't go beyond that. But I think customs recognizes they've gotta continue to push and get these other, entry types, into the system. Great question. Laura is asking, I assume they won't refund DHL slash UPS processing fees. I I don't know. That's a question for DHL and UPS. Fees. Knowing DHL and UPS, I'm going to guess no. But, again, when in doubt, reach out to them. You never know. If you. don't ask, I just need to be yeah. I mean, they they have statements. I know DHL, UPS, and FedEx all have statements up on their websites about what they're doing on on the refunds. I just I you know, I can't speak on on their behalf on on those kinds. of issues, Yeah. but would encourage you to look at their websites and then certainly reach out and have those conversations. I'm here. Next question is from Jan. Will a replay of the q and a be available? Yes. You'll be getting an email following the session with, a link to the calculator I mentioned as well as a replay with the q and a included. So don't worry if you missed an answer to something. You'll be able to go back and get everything that you need. Monica, if I can, just one one quick note for folks. If you're looking for additional resources, in addition to, you know, what's up on the CBP CBP's website, they have their their CSMS message system where they send out updates on different announcements, and we certainly encourage customs when they make changes to the website or have any updates that they use that. That's what they use to kinda educate the trade community. So I would encourage you to kinda register for the CSMS messages. You might get ones that mean absolutely nothing to you, but just it's a good way to kinda get that intel from customs if they're pushing stuff out. That's a great call out. Awesome. Let me check if we have any more q and a. It looks like Haven posted a one stop shop for all things small business at NRF, So check that out. And I believe that those were all of the q and a questions. So we'll give one more minute. Oh, we actually had another one come in. From Baruch, do my custom broker, will my custom broker charge me a commission for processing the refund? yeah. We we've certainly heard that brokers have been, putting a a fee in place for processing the cape documentation. The, I've heard anywhere from from 10 to 15%. Again, just a conversation with the broker. We've certainly heard that that is, that is the case. How they're doing? Great question. K. Another question. Great. Keep them coming. From Greg. Can you please say again where to get the importer of record number? That should be in your Ace, Ace account. Perfect. Let me see if anything else comes in. Because we have a few minutes left. Wanna make sure everybody gets a chance to ask their questions. Alright. From anonymous, is there any alternative if IOR does not have a US bank account? Not that I've heard at this point. They're only, they're requiring a US bank account. Good to know. Alright. I believe that was all the questions we had. But if for some reason your question wasn't answered, you can email, myself, monica dot barker, I'll put it in the chat, at saltbox dot com, and I'll make sure your questions get back to Jonathan and Angela and get answered. So that is a quick. No. question. I'm sorry. I have a quick question for. Jonathan. Jonathan, do you know if, Baker Tilly is still doing the, trade policy and tariff update call on Thursday? Yes. They do. Yes. Okay. Peter Mento with Baker Tilly, who's who's a great resource on a lot of this. He does a a free webinar on Thursdays at noon, him and his team, to kinda talk about all the the latest and greatest on everything that's going on. So, Monica, I'm happy to share that link with you if you wanna share that with folks. But, you know, would encourage you to look for Pete Mento on LinkedIn. He he provides fantastic commentary, on there too. So. I I will make sure I. get that over to you. Yeah. Perfect. Yeah. That's super helpful. And an easily digestible resource as well, we love. Absolutely. Absolutely. Awesome. Well, that concludes our session today. Like I mentioned, if you guys have any further questions questions and we didn't get to them, please email me, my emails in the chat, and I'll make sure they get to both Jonathan and Angela and get an answer back to you. We'll be sharing the resources in a follow-up email, so look out for that coming within the next couple hours, and hope you all have a nice day. Thank you, Angela and John, for joining. Thank, you. hopefully, we get more answers soon about phase two. Fingers crossed. And we'll probably have another session to cover that, I'm sure, when the time comes. But thank you all for joining us today. Great. Thank you. Thanks.