CARMICHAEL COMPASS: ISSUE 26-004 – January 29, 2026

REMINDER: CBP Electronic Refunds Will be Effective on February 6

Customs and Border Protection’s (CBP) program eliminating refund checks and implementing electronic refunds through the ACE portal will start next Friday, February 6.  All duties and fees refunds will only be issued through an ACE Portal account. CBP encourages all importers to have their own ACE Portal account. Importers with their portal accounts properly set up will have the refunds deposited directly to their own bank accounts.  If an importer does not have an ACE portal account they can assign the refunds to another user, but processing refunds through a third party will delay the receipt of funds.

Importers with current ACE portal accounts that receive ACH refunds need to understand that this program will no longer apply. Importers with existing accounts should ensure they have followed the new set up instructions to continue receiving electronic payments from CBP.  To help with the transition, CBP has prepared a series of instructions for setting up and working with ACE and the new refund process:

CBP Resources: ACE Portal Access and ACH Refund Enrollment

If you are having difficulty in getting an ACE Portal account or in setting up your current portal account, please let us know.  If you are not set up for electronic refunds for your entries, CBP will move that refund into a suspense account. 

484(f) Committee Publishes Proposed Changes, Effective February 1

The Committee for the Statistical Annotation of Tariff Schedules, known colloquially as the 484(f) Committee, has released their list of proposed changes to the HTSUS to become effective February 1, 2026.

The list of proposed changes encompasses HTS numbers from twenty-three chapters. These changes are not finalized until they are posted on the 484(f) Committee webpage. We will inform you when these changes are finalized.

CPSC Withdraws Accreditation from Multiple Chinese Laboratoires

On January 15, the U.S. Consumer Product Safety Commission (CPSC) announced the removal of accreditation for four Chinese testing laboratories. This removal comes after finding that these labs falsified reports, concealed the loss of accreditation by international authorities, and/or certified products that would later fail independent safety testing.

Certifications from the above entities are no longer accepted by CPSC. Any relying on reports from these entities must obtain new testing from properly accredited laboratories before importing or selling regulated products in the United States.

To see the full announcement from CPSC, click here.

Non-resident importers must take action to receive duty refunds starting February 6, 2026

On January 2, 2026, U.S. Customs and Border Protection (CBP) issued an interim final rule amending its regulations to require that all refunds be issued electronically, effective February 6, 2026. This means that CBP will no longer send an Importer their refunds by check in US dollars.

How does this affect non-resident importers?

A non-resident importer is a company that resides outside the United States of America but assumes responsibility as the Importer of Record on Customs entries.  Most non-resident importers do not have a U.S. bank account. 

Beginning February 6, 2026, CBP will issue all refunds electronically to a U.S. bank account. If your company does not have a U.S. bank account, you will not be able to receive your duty refunds directly from CBP. Importers without a U.S. bank account must either open one or designate an agent with a U.S. bank account to receive refunds on their behalf.

Failure to provide CBP with the required U.S. banking account information or nominating an agent with a U.S. bank account will result in a certified refund being rejected and the funds being held in a government holding account. No interest will accrue on refunds held due to an Importer failing to provide a U.S. bank account or to designate an agent to receive their refunds.

As your customs broker, Carmichael International Service can act as your designated agent and receive duty refunds from CBP.  If you are interested in Carmichael’s duty refund services, please get in touch with your designated Carmichael representative.