HTSAlert

IEEPA tariff refund: who can claim it and how

· built from CBP, Supreme Court and statute texts listed under Sources

If you were the importer of record on entries that paid IEEPA duties, you can request a refund from US Customs and Border Protection by uploading a CAPE Declaration in the ACE Portal. Refunds include interest and are paid by ACH. CAPE does not accept entries liquidated more than 80 days ago, so check each entry's status first.

THE SHORT VERSION

IEEPA tariff refunds are refunds of duties paid under the International Emergency Economic Powers Act, which the US Supreme Court held on February 20, 2026 does not authorize tariffs. US Customs and Border Protection processes them through CAPE, a tool in the ACE Portal. Only the importer of record, or the customs broker that filed the entries, can file. A CAPE Declaration is a CSV list of entry numbers, up to 9,999 per file. CAPE currently accepts unliquidated entries and entries liquidated within the last 80 days. Entries past that window are not accepted, and CBP offers no guidance on whether a Court of International Trade case is needed for them. Refunds are paid by ACH to a bank account enrolled in ACE, include interest, and are generally issued 60 to 90 days after a Declaration is accepted. CBP charges no fee. This summary reflects CBP pages read on October 2, 2026 and is not legal advice.

This page is an informational summary of public CBP, court and statutory sources. It is not legal or customs advice and does not create a broker or attorney relationship. HTSAlert does not file refund claims. Confirm your entries and deadlines with your licensed customs broker or trade counsel.

How the refunds came about

  1. The Supreme Court holds that IEEPA does not authorize the President to impose tariffs (judgment in No. 25-250 affirmed; No. 24-1287 vacated with instructions to dismiss for lack of jurisdiction). [6]

  2. Executive Order 14389, Ending Certain Tariff Actions, states that the IEEPA tariff duties are no longer in effect and, as soon as practicable, no longer collected. Section 2(d) states that Section 232 and Section 301 duties are not affected. [1]

  3. The Federal Circuit issues its formal mandate to the Court of International Trade (CIT) on IEEPA duties. [7]

  4. In Atmus Filtration, Inc. v. United States the CIT orders CBP to liquidate unliquidated IEEPA entries without the IEEPA duties and to reliquidate non-final liquidated entries the same way. On March 6 the CIT suspends the order's immediate-compliance requirement so CBP can build a processing tool. [7]

  5. In Euro-Notions Florida, Inc. v. United States the CIT issues a parallel order, again suspended to the extent it requires immediate compliance. [7]

  6. CBP activates CAPE Phase 1 in the ACE Portal: unliquidated entries and entries within 80 days of liquidation. [8] [2]

  7. CAPE Phase 2 deploys: entries flagged for reconciliation, where the reconciliation entry has not yet been filed, can be included. [9]

  8. CBP publishes updated guidance on warehouse withdrawal entries filed on CAPE Declarations. [10] [4]

Refund checklist for importers

The steps below follow CBP’s own CAPE documentation. Your broker may do most of them for you; the point is to know what to ask.

  1. 1. Confirm you were the importer of record, or use the broker who was the filer

    Only the importer of record (IOR) for the entries, or the licensed customs broker that filed them for the IOR, can submit a CAPE Declaration. If a freight forwarder, a DDP seller or a marketplace was the IOR, the refund is theirs in CBP's process; recovering any share is a commercial matter between you and them, which CBP's published process does not address. [5] [3]

  2. 2. Get an ACE Portal account with an Importer sub-account

    CAPE lives in the ACE Secure Data Portal, not in ABI. If your Trade Account Owner lapsed or you cannot find them, CBP's FAQ describes the reactivation and lookup requests. [3] [4]

  3. 3. Enroll a U.S. bank account for refunds

    Refunds are paid by ACH only, to bank details held in the ACH Refund Authorization tab of an Importer sub-account. This is separate from any account used to pay CBP. Refunds are not processed without it. [4] [5]

  4. 4. List the entries that paid IEEPA duties

    CBP points to ACE report ES-003, Entry Summary Line Tariff Details, which includes an IEEPA tariff indicator and shows every entry line with assessed duties. Use that indicator rather than a third party's label for which duties were IEEPA. [4]

  5. 5. Check each entry's liquidation status

    CAPE accepts unliquidated entries, entries with a suspended, extended or under-review status, and entries liquidated up to 80 days ago. That 80-day cap leaves CBP time to reliquidate inside the 90-day voluntary reliquidation period of 19 U.S.C. § 1501. Entries whose liquidation is final are rejected. [4] [3] [12]

  6. 6. Screen out entries CAPE does not take

    Not accepted: reconciliation summaries (entry type 09) and entries flagged for reconciliation with a type 09 already on file, entries on a drawback claim, entries under an open protest, warehouse entries (types 21 and 22), AD/CVD entries pending liquidation under 19 U.S.C. § 1504(d), and entries not filed in ACE. A Post Summary Correction cannot be used to start an IEEPA refund request. [4]

  7. 7. Build the CSV and file the Declaration

    The CSV needs only entry numbers: 11 characters, no dashes (put an apostrophe before a leading zero), up to 9,999 per Declaration, no duplicates. Each entry can sit on only one accepted Declaration, and an accepted Declaration cannot be amended or cancelled. Acceptance returns a CAPE claim number. [3] [4]

  8. 8. Track it in ACE reports; CBP will not email you

    Use ES-022 (CAPE Entry Summary), REV-603 (Trade Refund) and REV-613 (rejected ACH refunds). CBP says refunds are generally issued 60 to 90 days after acceptance, and most appear in the bank account 3 to 5 weeks after liquidation or reliquidation. [3] [4] [2]

  9. 9. Expect netting and a possible bill

    Refunds include interest under 19 U.S.C. § 1505 and are netted against any other over- or underpayment on the entry at liquidation, and against legally fixed, undisputed debts to CBP. Because other duties still apply, a Declaration can end in a bill if the entry as a whole was underpaid. [3] [2] [13]

  10. 10. Ignore anyone asking for a fee or your credentials

    CBP charges nothing to process tariff refunds and warns of scammers soliciting account and bank information. File only through your own ACE Portal account or your broker. [3] [11]

What is not settled

These are the places where the official sources are silent or the process is still moving. We do not guess; get advice on these.

Entries liquidated more than 80 days ago

CAPE rejects them as final. By statute a liquidation is final unless a protest is filed within 180 days after it (19 U.S.C. § 1514), and CBP says it offers no legal guidance on whether a Court of International Trade case must be filed for entries outside CAPE's current scope. We found no official statement on how these entries will be handled. Ask your broker or trade counsel now, because the 180-day protest clock runs from each entry's own liquidation date. [4] [3] [14]

Whether CAPE will widen

CBP describes CAPE as phased and says its notice is updated as enhancements ship; the CIT's orders were suspended only as to immediate compliance. What later phases cover, and when, is for CBP to announce. [2] [4] [7]

Money owed between importers and the parties they bought from

CBP pays the importer of record, or a Form 4811 notify party the IOR designated. Contracts, DDP terms and pass-through arrangements are outside the CBP process and outside what this page can tell you. [4]

Common questions

Are IEEPA tariffs still being collected?

No. After the Supreme Court held on February 20, 2026 that IEEPA does not authorize tariffs, Executive Order 14389 stated that the IEEPA duties are no longer in effect and, as soon as practicable, no longer collected. The order does not give the date CBP stopped collecting on entries, so check the entry dates on your own paperwork. Section 232 and Section 301 duties are not affected by the order and are still collected; HTSAlert's calculator adds those and does not add IEEPA duties. Where an old Chapter 99 IEEPA heading still appears in our data it is shown as historical, not as a current charge. [1] [6]

Who gets the IEEPA tariff refund?

CBP pays the importer of record, or a Form 4811 notify party the importer designated on the entry. Only the importer of record or the customs broker that filed the entries can submit the CAPE Declaration. A buyer who did not appear as importer of record on the entry is not a party to CBP's process. [4] [5]

How long does an IEEPA refund take?

CBP says valid refunds are generally issued 60 to 90 days after a CAPE Declaration is accepted, unless a compliance concern needs more review. Entries that are suspended, extended, under review or warehouse entries keep their liquidation status and are refunded when they liquidate. Most refunds reach the bank account 3 to 5 weeks after liquidation or reliquidation. [2] [3]

Do I need to file a case at the Court of International Trade?

For CAPE Phase 1 entries, meaning unliquidated entries or entries inside the 90-day voluntary reliquidation period, CBP says you do not need to file a CIT case to receive an IEEPA refund due to you. For any other entries CBP offers no legal guidance on the question, so take advice. [3]

Is there a tariff refund process for businesses that import through a broker?

Yes. A customs broker can submit one Declaration of up to 9,999 entries covering entries it filed for several importers. The broker must be the filer of record on those entries. Importers can also file their own Declaration in their own ACE Portal account. [3] [5]

Will I get interest on an IEEPA refund?

Yes. Interest is paid on the refunded duties under 19 U.S.C. § 1505, generally from the date of deposit or estimated duty payment to the date of liquidation or reliquidation, at IRS-published rates. It arrives inside the same ACH payment, not separately. [3] [13]

Are Section 232 and Section 301 duties refundable through CAPE?

No. CAPE removes IEEPA Chapter 99 duties from an entry and the entry is still subject to every other duty that applies, including other trade remedies. An entry needs at least one dutiable IEEPA Chapter 99 line to be accepted. [3] [4]

Refunds look back. Duty changes on your codes keep coming.

HTSAlert checks the official USITC tariff schedule every day and alerts you when the duty on an HTS code you import changes, with the effective date and the Chapter 99 subheading. It does not file refund claims. Add a code to start watching it; the free plan covers 5 codes.

Not sure of the code or the current stack? Try the free duty calculator.

Sources

Read on October 2, 2026. CBP revises these pages; check them before you file.

  1. [1] Executive Order 14389 - Ending Certain Tariff Actions (91 FR 9437) · Federal Register · Signed February 20, 2026; published February 25, 2026
  2. [2] IEEPA Duty Refunds · U.S. Customs and Border Protection · CBP landing page for CAPE and IEEPA refunds
  3. [3] IEEPA Frequently Asked Questions · U.S. Customs and Border Protection · CBP FAQ, entries individually dated (latest seen: 9/30/2026)
  4. [4] Trade Information Notice: CAPE · U.S. Customs and Border Protection · Pub. 1009-1119, last updated July 10, 2026
  5. [5] Fact Sheet: IEEPA Duty Refunds · U.S. Customs and Border Protection · Pub. 5515-0426, April 2026
  6. [6] Learning Resources, Inc. v. Trump, Nos. 24-1287 and 25-250 · Supreme Court of the United States · Slip opinion, decided February 20, 2026
  7. [7] CSMS # 68340863 - UPDATE - CAPE for IEEPA Refunds · U.S. Customs and Border Protection · Recites the Federal Circuit mandate and the CIT orders; April 13, 2026
  8. [8] CSMS # 68396594 - AVAILABLE NOW - CAPE for IEEPA Refunds · U.S. Customs and Border Protection · CAPE Phase 1 activation; April 20, 2026
  9. [9] CSMS # 69066837 - DEPLOYED - CAPE: Entries Flagged for Reconciliation · U.S. Customs and Border Protection · CAPE Phase 2; June 29, 2026
  10. [10] CSMS # 69127837 - UPDATE - CAPE: Warehouse Entries · U.S. Customs and Border Protection · Warehouse entry guidance; July 2, 2026
  11. [11] CSMS # 68569567 - Best Practices for Protecting Your Information Regarding IEEPA Refunds · U.S. Customs and Border Protection · Scam warning; May 7, 2026
  12. [12] 19 U.S.C. § 1501 - Voluntary reliquidations · Cornell Legal Information Institute (U.S. Code) · 90-day window for CBP voluntary reliquidation
  13. [13] 19 U.S.C. § 1505 - Payment of duties and refunds · Cornell Legal Information Institute (U.S. Code) · Interest on refunds at liquidation or reliquidation
  14. [14] 19 U.S.C. § 1514 - Protest against decisions of Customs Service · Cornell Legal Information Institute (U.S. Code) · Liquidation is final unless protested within 180 days