Your IEEPA refund questions, answered

Most likely, if your company was the importer of record.

On February 20, 2026, the Supreme Court ruled that IEEPA, a 1977 emergency powers law, doesn't give the President power to set tariffs. Customs stopped collecting them on February 24, 2026, and is now paying them back. Whether you can file right now depends on where each entry stands. See which entries qualify

You need to submit a claim. You or your broker file a refund request, called a CAPE Declaration, and CBP has to accept it.

Qualifying for a refund isn't the same as getting one. Nothing moves until that request is filed.

The importer of record. That's the company named on the customs entry as responsible for the goods and the duties.

The only exception: the importer of record can name another party to receive refunds on its behalf using CBP Form 4811. That has to be set up before the claim is filed.

CBP doesn't pay brokers, consignees, or customers directly. If customers paid part of the tariff cost through higher prices, any sharing of the refund is between you and them, not CBP. That's worth a conversation with your attorney.

Yes. CBP pays interest along with the refunded IEEPA duties.

Yes. The refund covers every tariff set under IEEPA, including:

• The tariffs on China, Canada, and Mexico tied to fentanyl and border issues
• The reciprocal tariffs on goods from almost every country
• The extra IEEPA tariffs on Brazil and India

Look for tariff lines starting with 9903.01 or 9903.02. Those codes mark IEEPA duties on your entry paperwork.

In ACE, the ES-003 report lists every line on every entry. Export it, filter for those codes, and the dollar amounts on those lines are what you paid. If your company wasn't the importer of record, that report may come back empty. Your broker can pull it too.

Your final refund can differ from that total. See the next few answers for why.

Two things decide it. The entry needs at least one IEEPA tariff line, and its status has to fit a refund phase that's open to you.

Status mostly comes down to liquidation, which is when CBP locks in the final duty on an entry. See how status and phases work

IEEPA tariffs were stacked on top of everything else, and the refund only removes the IEEPA part. These still apply and stay paid:

• Your regular duty rate
• Section 301 tariffs
• Section 232 tariffs, like those on steel and aluminum
• Antidumping and countervailing duties (AD/CVD)

When CBP processes your claim, it recalculates the whole entry without IEEPA. If any other duty was underpaid, your refund shrinks by that amount, and in some cases you could get a bill instead.

For USMCA: goods from Canada or Mexico that were entered as USMCA-qualifying generally weren't charged the Canada and Mexico IEEPA tariffs, so there may be nothing to refund on those lines.

No, IEEPA tariffs ended February 24, 2026. Other tariffs replaced them.

• February 24 to July 24, 2026: a temporary 10% tariff on most imports under Section 122
• Since July 24, 2026: new Section 301 tariffs of 10% or 12.5% on goods from 60 countries, with some exemptions

Your regular duties, older Section 301 tariffs, Section 232 tariffs, and AD/CVD still apply too. Rates keep changing, so check with your broker before you price future shipments.

Not through CAPE. In May 2026 the Court of International Trade ruled the Section 122 tariffs went beyond the President's authority, but that ruling only helped the companies that brought the case, and the government appealed.

CAPE is only for IEEPA duties. If you paid Section 122 tariffs and want to explore recovering them, talk to a trade attorney.

You upload a list of entry numbers in ACE.

CAPE is CBP's refund process for IEEPA duties. It lives inside ACE, the online system importers and brokers already use for customs business. The upload is a spreadsheet file, and CBP calls it a CAPE Declaration. Once it's accepted, you get a claim number to track it. See the full walkthrough

Three things:

• An ACE Portal account
• Refund bank details set up in ACE, since CBP only pays refunds by direct deposit
• A list of every entry where you paid IEEPA duties

For most entries, your broker can file it. Only you or the broker who filed the original entries can submit a CAPE Declaration. If you used more than one broker, each one can only cover their own entries.

A trade attorney makes sense when entries are closed out, when a protest or court case might be needed, or when you're unsure about a deadline.

No. CBP has said CAPE is the way to claim IEEPA refunds, not Post Summary Corrections.

Most rejections come from data problems, not eligibility. The common ones:

• The filer or importer of record doesn't match what's on the entry
• Entry numbers are wrong or mistyped
• The upload file doesn't follow CBP's template
• The entry doesn't fit the current phase, or was already claimed
• No refund bank info on file

Your broker can look at the error and tell you whether it can be corrected and resubmitted. If the original entry itself has mistakes, like the wrong classification or value, sort that out with your broker before you file. CBP recalculates the whole entry when it processes your claim.

The withdrawals, not the original warehouse entries. The IEEPA duties were paid when goods came out of the warehouse, so that's where the refund comes from.

Since July 7, 2026, CAPE rejects warehouse entries (types 21 and 22) but accepts withdrawals (types 31, 32, 34, and 38). If you filed warehouse entries before then without the matching withdrawals, you'll need to resubmit using the withdrawals.

CBP is opening refunds in stages, based on where each entry stands.

• Phase 1 (since April 20, 2026): entries that haven't liquidated yet, or liquidated in the last 80 days
• Phase 2 (since June 29, 2026): entries flagged for reconciliation that don't have a reconciliation entry filed yet
• Phase 3 (since October 6, 2026): older, finally liquidated entries covered by a court order, only for importers with their own court case

Often yes, but it depends on how long ago. Liquidation is when CBP locks in the final duty on an entry. The clock starts that day.

• Within the last 80 days: file through CAPE in Phase 1
• More than 80 days ago, but within 180 days: CAPE won't take it, but a formal dispute, called a protest, may still be an option. Ask your broker or a trade attorney.
• More than 180 days ago: the entry is "finally liquidated," meaning closed out. Right now, refunds on these go through Phase 3 and only for importers with their own court case.

More on entry status

All three of these have to be true:

• The entry is finally liquidated
• You're a plaintiff in your own pending case at the Court of International Trade asking for IEEPA refunds
• The entry is covered by a court order telling CBP to reliquidate it

To file on day one, you also had to give CBP your importer of record number by July 30, 2026.

You're not shut out, but you'll file later. CBP has said it'll send later submitters more instructions after Phase 3 opens. Keep an eye on CBP's IEEPA refunds page for that guidance.

Not through CAPE right now.

The government appealed, and a higher court (the Federal Circuit) is deciding whether importers who didn't sue can get refunds on closed-out entries. Until that's settled, it's worth talking to a trade attorney about your options and timing.

There's no single deadline. Each entry has its own clocks.

• 80 days after liquidation: the entry drops out of CAPE Phase 1
• 180 days after liquidation: the protest window closes and the entry becomes finally liquidated
• For closed-out entries: several trade attorneys point to a two-year window to go to court, counted from when the duties were paid, so the earliest entries could start running out in early 2027

Waiting doesn't shrink the refund amount, but it can push an entry from a simple filing to a protest or a court case. Check the dates on your own entries with your broker or a trade attorney.

CBP estimates 60 to 90 days after it accepts your request, unless the claim needs extra review.

The clock starts at acceptance, not when you submit. Refunds are grouped by liquidation date, so if your entries liquidate on different days, the money may come in several payments. Some importers have reported longer waits.

By direct deposit only. If your refund bank details aren't set up in ACE, an approved refund just sits there.

In September, CBP reported about $1.3 billion in approved refunds on hold for exactly that reason.

Yes. Before paying, CBP checks whether your company owes it anything. If you do, it subtracts that from the refund, entry by entry.

If you have open CBP bills, expect a smaller payment.

CBP hasn't added new recordkeeping rules for refunds. Keep following the rules you already have, which generally means holding import records for five years.

A CAPE Declaration is your statement that the entries qualify, and trade attorneys expect CBP to review some refunded entries. Keep your entry summaries, invoices, claim numbers, and refund reports organized by entry number.

Yes, through ACE. Each CAPE Declaration gets a claim number, and ACE has reports that show where your claims and refunds stand.

CBP won't email you status updates. If your broker filed for you, ask them for updates.

A lot, and it's still moving. As of mid-September 2026, CBP reported about $134.7 billion in refunds accepted and about $122 billion sent to the Treasury for payment, covering about 27.2 million entries. CBP collected about $166 billion in IEEPA duties overall.