Tennessee Joins ACE Electronic Refund Push in Travel Trade

Tennessee has moved into alignment with a growing list of U.S. states as importers across the travel and aviation supply chain confront a hard deadline to enroll in the Automated Commercial Environment (ACE) Portal for mandatory electronic refunds from U.S. Customs and Border Protection.

Federal Rule Drives Nationwide Shift to ACH Refunds

The latest changes stem from an interim federal rule issued by U.S. Customs and Border Protection, which requires nearly all refunds to be issued electronically through Automated Clearing House, using bank details stored in ACE. The rule, published in early January 2026, took effect on February 6, 2026, ending the long-standing practice of paper refund checks for duty payments and other customs-related overpayments.

Publicly available guidance describes the move as a modernization step designed to reduce processing times, minimize lost or misdirected checks, and improve audit trails for importers and government alike. From tariff relief associated with court-ordered duty refunds to routine post-summary corrections, the expectation now is that funds will travel by direct deposit to bank accounts authorized in ACE.

The change applies across the United States, but it is being felt acutely in states with dense logistics and tourism activity. This includes Tennessee and other states such as Connecticut, Kentucky, Minnesota, Mississippi, Nevada, New Hampshire, New Jersey, New Mexico, Washington, and Wisconsin, where importers serving airports, airlines, cruise operators, hotels, and tour companies routinely rely on customs refunds as part of their cash-flow planning.

Reports from trade advisors note that CBP has already rejected thousands of refund transactions since February due to incomplete or invalid banking details, underscoring that enrollment in ACE is no longer a formality but a prerequisite for receiving money back.

Tennessee Importers Join Growing Roster of ACE-Dependent States

While the federal rule applies nationally, Tennessee’s participation has particular significance for the domestic travel and aviation ecosystem. The state is a transit hub for passenger and cargo flows that feed major gateways around the country, and many of its companies now find that customs refunds tied to imported aircraft parts, in-flight products, retail goods, and construction materials for tourism infrastructure will only move if ACE profiles are properly configured.

Industry analyses group Tennessee with a broader roster of states, including Connecticut, Kentucky, Minnesota, Mississippi, Nevada, New Hampshire, New Jersey, New Mexico, Washington, and Wisconsin, where logistics operators and importers are seen as especially exposed to the transition. Many of these states have international airports, cruise terminals, or inland ports that depend on predictable refund cycles when duties are recalculated or trade disputes are resolved.

According to published commentary from logistics firms and legal practices, the number of importers that have completed ACE refund enrollment still trails far behind the number of entities that paid duties in recent months. In one snapshot, only a small fraction of the hundreds of thousands of importers tracked by CBP had finished the steps needed to receive electronic refunds, indicating that Tennessee businesses are part of a much larger national catch-up effort.

Trade groups focused on consumer goods, industrial equipment, and transportation services have begun circulating checklists urging members to verify their ACE account status, designate trade account owners, and confirm that each importer of record number has accurate banking information on file.

What Mandatory ACE Enrollment Means for Travel and Aviation

For the United States travel and aviation supply chain, the move to mandatory ACE-based refunds is more than a technical accounting change. Airlines, airport concessionaires, hotel chains, destination management companies, and tour operators rely on a steady flow of imported goods ranging from aircraft components and safety equipment to furnishings, food, beverages, and retail merchandise.

When duties are reduced or eliminated, or when court decisions trigger large-scale tariff refunds, the timing and reliability of those payments can shape investment plans and pricing decisions. Analysts note that in Tennessee and peer states, importers tied to airport projects and tourism developments may now see refund timing closely linked to their ACE readiness. Missing or outdated bank information, or gaps in portal access, can delay cash that many businesses have already factored into budgets.

Observers also point out that the new requirements affect intermediaries such as customs brokers and freight forwarders that serve travel sector clients. The updated rules and ACE tools clarify that the party receiving a refund must be properly configured in the system, whether that is the importer of record or a designated third party. As a result, travel-related businesses are being encouraged to review long-standing instructions about who receives refunds and to align those instructions with current ACE configurations.

Some commentary suggests that, in the near term, the shift could introduce friction as companies untangle legacy processes built around paper checks. Over time, however, many in the trade community expect electronic refunds to integrate more seamlessly with treasury management systems, giving travel and aviation firms clearer visibility into expected inflows.

Enrollment Steps and Risks for Noncompliant Companies

Publicly available enrollment guides describe a multi-step process for companies that have not yet completed ACE setup. Businesses must obtain or confirm access to the ACE Secure Data Portal, assign a trade account owner, and ensure that each relevant importer number has an active profile. Within that profile, an ACH refund authorization must be created, capturing routing and account numbers for a U.S. financial institution.

CBP communications emphasize that the accuracy of this data is critical. Refunds can be rejected if the account has been closed, if numbers are entered incorrectly, or if enrollment has not been finalized. When that happens, funds are effectively paused until the importer or its representative corrects the underlying record in ACE. For Tennessee companies and their counterparts in other participating states, this introduces a new operational risk tied directly to data quality.

Advisory notes from law firms and trade associations indicate that companies which relied heavily on brokers to receive and distribute refunds may need to revisit that model. The electronic framework makes it easier for CBP to send funds directly to the true importer of record, but that benefit is only realized if the importer maintains its own ACE access and ACH profile. Businesses embedded in the travel and aviation supply chain, where margins can be tight and project timelines long, are being encouraged to treat ACE enrollment as a finance and compliance priority rather than a back-office chore.

For organizations that are unable to obtain ACE access or establish ACH arrangements, public information suggests that limited exceptions continue to exist, but these are narrowly defined and may not cover most commercial importers. As a result, companies that delay action risk standing apart from a system that is rapidly normalizing electronic-only refunds.

Operational Pressure Builds as CAPE and IEEPA Refunds Loom

The electronic refund requirement is unfolding at the same time as CBP works on systems to manage large, high-profile refund programs, including those tied to trade litigation under emergency tariff authorities. Public court filings and trade press coverage refer to a phased rollout of new refund tools in ACE, including a claims portal and automated processing for both liquidated and unliquidated entries.

For Tennessee importers and firms in other listed states, this convergence means that future waves of tariff relief connected to litigation or policy shifts will almost certainly arrive through the ACE infrastructure now being put in place. Companies that move quickly to validate their information may be positioned to receive refunds earlier in the cycle, while late adopters could face weeks or months of avoidable delay.

Commentary from customs specialists highlights that ACE is also being refined to address complex routing scenarios, such as refunds that historically flowed through customs brokers or other intermediaries under prior instructions. These refinements are expected to be particularly relevant for multinational travel and aviation firms that import through multiple U.S. gateways but centralize their treasury operations in a small number of locations.

As Tennessee joins the growing roster of states where importers are actively adjusting to ACE-based refunds, the broader U.S. travel and aviation supply chain is watching closely. The success or struggle of early adopters will likely shape how quickly the rest of the trade community embraces a refund environment in which electronic enrollment is not optional but fundamental.