IEEPA Tariff Refunds 2026: How to Claim What You're Owed Before the Window Closes
- 22 hours ago
- 7 min read
Published: June 30, 2026
In February 2026, the U.S. Supreme Court ruled that the IEEPA tariffs — the sweeping import duties that had defined U.S. trade policy since April 2025 — were unlawful. The ruling covered approximately $166 billion in duties collected from more than 330,000 importers across 53 million shipments.
That money is refundable. But it is not being refunded automatically.
On April 20, 2026, CBP launched CAPE — the Consolidated Administration and Processing of Entries system — as the exclusive mechanism for IEEPA tariff refunds. Two months in, 125,576 CAPE declarations have passed validation, covering 16.74 million entries. Of those, 10.6 million have been processed and $23.68 billion in IEEPA duties has been approved for refund.
That leaves over $140 billion still unclaimed — and for many importers, the window to recover their share is narrowing with every passing day.
This is what you need to know about IEEPA tariff refunds, how the CAPE system works, and what to do right now.
What the IEEPA Tariff Refunds Are — and What They Are Not
The IEEPA tariffs were first imposed under Executive Orders 14193, 14194, and 14195 (February 1, 2026) targeting Canada, Mexico, and China, and expanded under Executive Order 14257 (April 2, 2025) as a broader set of reciprocal tariffs covering most trading partners. The baseline rate was 10%, with country-specific rates varying throughout the year.
On February 20, 2026, the Supreme Court held 6-3 in V.O.S. Selections Inc. v. United States that IEEPA does not authorize the imposition of tariffs. The Court remanded the question of refunds to the Court of International Trade, which ordered CBP to develop a refund mechanism.
What IEEPA tariff refunds cover: The CAPE system processes refunds for duties paid under the IEEPA reciprocal tariff orders — the baseline 10% rate plus country-specific rates. Refunds include applicable statutory interest on top of the duties paid.
What IEEPA tariff refunds do NOT cover: This is where many importers make critical errors. CAPE does not and will not process refunds for:
Section 232 tariffs (steel 50%, aluminum 50%, automobiles 25%, semiconductors 25%, copper 50%)
Section 301 tariffs on China (25–100%)
The current Section 122 tariff (10%, imposed February 24, 2026) — a separate legal authority entirely
If you paid Section 232 or Section 301 duties during the IEEPA period, those are not part of this refund process. The IEEPA refund covers only the Chapter 99 IEEPA HTS codes on your entry summaries — not the full duty amount on every line.
How IEEPA Tariff Refunds 2026 Work Through CAPE
What CAPE Is
CAPE (Consolidated Administration and Processing of Entries) is a purpose-built tool within the ACE Secure Data Portal — the same system importers already use for entry filings. CBP built CAPE specifically to handle the scale of the IEEPA refund process: 53 million entries across 330,000 importers could not be processed through traditional protest mechanisms without years of delay.
CAPE consolidates claims by Importer of Record (IOR) and liquidation date, recalculates duties in bulk, and issues a single consolidated ACH payment. No supporting documentation is required beyond the list of entry numbers.
Phase 1: What It Covers
CBP launched Phase 1 on April 20, 2026. Phase 1 is limited to:
Unliquidated entries — entries where CBP has not yet finalized the duty assessment
Entries within 80 days of liquidation — entries that have liquidated but remain within the reliquidation window
Phase 1 is estimated to cover approximately 82% of total eligible duties — roughly $127 billion including statutory interest. The remaining ~18% sits in fully liquidated entries outside the 80-day window, which will need Phase 2 or direct CIT litigation.
Phase 2: What's Coming
Phase 2 launches June 29, 2026 — tomorrow — and expands CAPE to cover reconciliation entries. CBP has stated it will need each importer's IOR number approximately two weeks prior to deployment. Further phases are expected to address fully liquidated entries, but no timeline has been published for those.
CBP's position: importers whose entries have finally liquidated outside the 80-day window and who have not filed their own CIT case will NOT be eligible for a refund unless a court order specifically covers them. This position is on appeal — but until it is settled, CBP will not expand CAPE to cover those entries.
The Deadline Problem: Why Your Eligibility Is Disappearing Now
Most importers assume IEEPA refunds work like a tax refund: one deadline, one filing, one check.
They do not work that way.
Every customs entry has its own liquidation date — the date CBP finalizes the duty assessment on that specific shipment. The refund window runs from that individual liquidation date. A company that imported throughout 2025 and early 2026 may have hundreds or thousands of entries, each with its own deadline rolling forward continuously.
The practical effect: your business is losing refund eligibility entry by entry, right now. Entries that were within the 80-day window when Phase 1 launched in April are already falling outside that window. Every week of inaction costs money.
For entries that have liquidated and are in the 90- to 180-day post-liquidation period, importers must file a CBP protest under 19 U.S.C. § 1514 to preserve their refund claim. Protests are a separate pathway from CAPE and require entry-level documentation. Missing this window may permanently forfeit the refund right on those specific entries.
How to Claim Your IEEPA Tariff Refund: Step by Step
Step 1: Confirm ACE Portal Access
Only the Importer of Record (IOR) or the licensed customs broker who filed the original entries can submit a CAPE Declaration. Third parties without original filing authority cannot file. If you don't have an ACE Portal account with the Importer sub-account, register immediately — this takes time.
Step 2: Enroll in ACH Electronic Refunds
As of February 6, 2026, CBP no longer issues paper refund checks. All refunds are paid via ACH transfer. If your banking information is not enrolled in the ACE Portal's ACH Refund Authorization tab, CBP will place approved refunds in reject status — regardless of the validity of your claim. Enroll before filing.
Step 3: Pull Your Entry Records
Collect every entry summary filed between April 5, 2025 (when the first IEEPA tariffs took effect on China) and February 24, 2026 (when Section 122 replaced IEEPA). Filter for entries where at least one IEEPA Chapter 99 HTS code was declared. Your customs broker should be able to pull this from their filing records.
Step 4: Identify Phase 1-Eligible Entries
Sort your entries by liquidation status:
Unliquidated or within 80 days of liquidation → eligible for Phase 1 CAPE filing now
Liquidated between 80–180 days ago → eligible for CBP protest filing
Liquidated more than 180 days ago → wait for Phase 2 guidance or CIT litigation
Step 5: Prepare and Submit Your CAPE Declaration
CAPE Declarations are submitted as CSV files through the CAPE tab in the ACE Portal. Each Declaration is limited to 9,999 entries, but multiple Declarations can be filed. CBP runs two validation series:
File-level validation: confirms submitter authority, file format, and entry list
Entry-level validation: confirms each entry exists in ACE, contains IEEPA Chapter 99 codes, and is not duplicated
If the file-level validation fails, ACE rejects the entire Declaration. If individual entries fail entry-level validation, those entries are excluded from the accepted Declaration — but the rest proceed.
Critical: Once a CAPE Declaration is accepted, it cannot be amended. If you identify additional eligible entries after acceptance, you must file a new Declaration.
Step 6: Monitor and Wait
Once a Declaration is accepted, CBP removes the IEEPA Chapter 99 HTS provision from each entry, recalculates duties, and issues a consolidated refund. Timeline: 60 to 90 days from acceptance, subject to compliance review. Refunds appear as ACH deposits consolidated by IOR and liquidation date — not paid entry by entry.
Track status through ACE: "Sent to Treasury" means CBP processing is complete; "Treasury issued" means the refund has been paid.
Common Errors That Get Claims Rejected
The first 72 hours after CAPE launched saw portal congestion, duplicate tax ID errors, and rejection cascades for importers who filed without clean data. Two months in, the most common errors are:
Incomplete ACH enrollment. If banking information is missing or incorrect, approved refunds go into reject status. Fix this before filing.
Incorrect IOR designation. The IOR number on the CAPE Declaration must match the IOR on the original entry summary. Mismatches cause entry-level rejections.
Including ineligible entries. Entries subject to Section 232, Section 301, or non-IEEPA duties cannot be included. Adding them causes those specific entries to fail validation.
Rushing without clean data. Some importers filed immediately on April 20 with incomplete or incorrectly formatted CSV files. Only 63% of initial submissions passed the first validation step. Take time to verify data before submitting.
Waiting on entries near the 80-day window. Entries that are currently within the window will fall outside it as time passes. File before the window closes — not after.
What This Means If You Also Paid Section 122 Duties
Many importers are managing two parallel situations: IEEPA refunds for duties paid from April 2025 through February 2026, and Section 122 exposure for duties paid from February 24 through July 24, 2026.
These are completely separate legal proceedings, separate systems, and separate deadlines. CAPE does not touch Section 122. The Section 122 litigation — currently stayed at the Federal Circuit pending appeal — does not affect CAPE eligibility.
Do not conflate the two. Manage them on separate tracks. For a full breakdown of the Section 122 situation and what to do before July 24, see our analysis here.
How to Claim Your IEEPA Tariff Refund:
The Bottom Line
The IEEPA tariff refunds are real, the system is live, and CBP has already approved $23.68 billion in claims. But the process is not passive, not automatic, and not forgiving of delays.
Your eligibility is eroding entry by entry as liquidation windows close. Phase 2 launches June 29 — this week — expanding coverage to reconciliation entries. Importers with organized records will file first and get paid first.
The steps are clear: confirm ACE access, enroll ACH banking, pull entry records, identify eligible entries, prepare the CSV, and file. The complexity is in the execution — incomplete enrollment, formatting errors, and IOR mismatches are the most common reasons claims fail.
If you imported goods subject to IEEPA tariffs between April 2025 and February 2026, the refund is available. The only question is whether you act before the window closes on your entries.
Managing IEEPA refund filings alongside Section 122 and Section 301 exposure? Get in touch with the Movargo team — we work with customs brokers and trade counsel to map entry eligibility, coordinate CAPE filings, and ensure your tariff recovery process runs alongside your active shipment planning.
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