Bond Spotlight - Bond Limits Beware
The end of IEEPA duty collection on February 24, 2026, has created the impression that importer bond requirements should decline. In reality, current conditions strongly suggest that importers should not reduce bond limits at this time.
CBP continues to calculate bond sufficiency based on the prior 12 months of estimated duties, taxes and fees, which still include IEEPA amounts filed at entry—even if those duties are later removed through refunds and adjustments. This means bond requirements remain elevated and CBP has confirmed no change to this methodology. At the same time, new tariffs such as Section 122 and potentially expanded Section 301, may offset any perceived reduction in duty liability, further limiting the likelihood of lower bond requirements in the near term.
Reducing bond limits mid-term is particularly risky. Customs bonds secure not only duty payments but also potential penalties and compliance liabilities that remain in place until entries liquidate. Lowering bond coverage mid-term can increase financial risk rather than reduce it. As a result, bond changes are better evaluated at renewal, when the full scope of liability—including tariff changes and potential refunds—can be assessed. It’s also important to note, collateral posted to support increased bond amounts will not be released simply due to IEEPA changes. Collateral will be maintained until the total exposure under the bond is fully eliminated.
Meanwhile, the refund environment is still uncertain. While Phase 1 of the refund process has begun, it only accounts for a portion of the potential IEEPA duties paid. The fate of the balance remains unknown, creating financial uncertainty where future cash recoveries are possible but not yet guaranteed.
Given this volatile environment, the prudent approach is to maintain current bond limits, at least until renewal. Reducing them now could leave importers with unnecessary stacking of liability and under-secured, just as CBP’s methodology, refund processes, and exposure calculations are still in flux.