IEEPA Tariff Refund Eligibility — Who Qualifies for CAPE Claims

Core Eligibility Requirements

You must be the importer of record (IOR)

Your EIN or SSN must appear as the IOR on CBP Form 7501 for the entries you're claiming. The IOR is the party legally responsible for the entry and duty payment. If a domestic distributor or supplier was the IOR, you are not eligible — they are.

Goods must have entered during the IEEPA period

The consumption entry date on the 7501 must fall within the coverage window: February 4, 2025–February 20, 2026 for Canada, China, and Mexico; April 5, 2025–February 20, 2026 for all other covered countries.

IEEPA duties must have been actually collected

The IEEPA duty line on the 7501 must show a positive dollar amount — not $0. Entries where IEEPA duties were waived, credited, or exempt (due to FTA treatment) have nothing to refund.

Goods must be eligible entry types

CAPE Phase 1 covers standard consumption entries and warehouse withdrawal entries. Some specialized entry types (FTZ, TIB) may require a future Phase 2 process. De minimis (Section 321) entries paid no duty and are not eligible.

What IS Refundable

IEEPA reciprocal tariff duties collected on goods from covered countries
Duties from both the February 4, 2025 (Canada/China/Mexico) and April 5, 2025 (all others) effective dates
Duties on standard consumption entries (Type 01)
Duties on formal warehouse withdrawal entries
Potential statutory interest under 19 U.S.C. § 1505 (not guaranteed, amount TBD)

What Is NOT Refundable

Section 301 tariffs on Chinese goods (separate legal authority, not part of SCOTUS ruling)
Section 232 steel and aluminum tariffs
Section 122 replacement tariffs (in effect from Feb 24, 2026)
MFN (most-favored nation) baseline duty rates that existed before IEEPA
USMCA-qualifying Canadian and Mexican goods that paid $0 IEEPA duty
KORUS FTA-qualifying South Korean goods that paid $0 IEEPA duty
Goods that entered via Section 321 de minimis (no duties assessed)
Antidumping and countervailing duties

Quick Eligibility Checklist

My EIN or SSN appears as the importer of record on the relevant CBP Form 7501 entries The entry dates fall within the applicable IEEPA coverage window for my sourcing countries The IEEPA duty line on my 7501 shows a positive dollar amount (not $0) The goods were not exempt under USMCA, KORUS, or another FTA The duties I'm claiming are specifically IEEPA-related, not Section 301 or Section 232 My ACE account is active and has banking information registered for ACH deposits

Phase 1 vs. Future Phases

CAPE Phase 1, launched April 20, 2026, covers standard consumption entries and most IEEPA reciprocal duties. Some specialized scenarios — foreign trade zone (FTZ) entries, temporary importation under bond (TIB), and certain edge-case entry types — may be addressed in future phases.

If you have entries in these specialized categories, document them now but don't wait on Phase 1 filing. File your Phase 1 eligible entries immediately, and watch for CBP guidance on Phase 2 for any remaining entries.

See our detailed guide: CAPE Phase 1 vs. Future Phases →

IEEPA Refund Eligibility