IEEPA Tariff Refund FAQ

The importer of record (IOR) listed on the CBP Form 7501 is the only party eligible to file for a refund through the CAPE portal. This is typically the U.S.-based buyer or the licensed customs broker acting on the importer's behalf. Foreign exporters, freight forwarders, and third-party logistics providers cannot file unless they were also the listed IOR.

Goods that qualify are those that (1) were entered for consumption between February 4, 2025 and February 20, 2026, (2) had IEEPA reciprocal tariffs actually assessed and collected by CBP, and (3) are not otherwise excluded from the court order. USMCA-qualifying Canadian and Mexican goods that were exempt from IEEPA duties do not qualify. Section 301 tariffs on Chinese goods remain in effect and are not refundable through CAPE.

No. Section 301 tariffs on Chinese goods were imposed under a different legal authority and were not challenged in the V.O.S. Selections case. The Supreme Court's February 2026 ruling only addressed IEEPA reciprocal tariffs. Section 301 rates (ranging from 7.5% to 100% depending on the product list) remain fully in effect.

USMCA-qualifying goods that entered duty-free because of the trade agreement were never assessed IEEPA duties, so there is nothing to refund. However, Canadian and Mexican goods that did not meet USMCA rules of origin and paid the 25% IEEPA rate may qualify. Review your CBP 7501 forms carefully — if the IEEPA column shows $0 assessed, that entry is not refundable.

Yes. South Korea's KORUS FTA and other U.S. free trade agreements can reduce or eliminate the underlying duty rate. If KORUS-qualifying goods paid no IEEPA duty because of preferential treatment, there is no refund for those specific entries. You must check line by line on your 7501 forms to determine which entries had duties actually collected.

Shipments that cleared U.S. Customs under the Section 321 de minimis exemption (previously $800 per person per day) paid no duties and therefore cannot generate a refund. However, CBP significantly tightened de minimis rules beginning in 2025 for goods from China and other high-rate countries, so many shipments that formerly qualified as de minimis may have paid duties and could be eligible.

The International Emergency Economic Powers Act (IEEPA), enacted in 1977, grants the President broad authority to regulate commerce during a national emergency. Beginning in early 2025, the Trump administration used IEEPA to impose "reciprocal" tariffs ranging from 10% to 46% on imports from dozens of countries. The administration argued that persistent trade deficits constituted a national emergency. Legal challenges argued that IEEPA was never intended to authorize broad tariffs in peacetime.

In V.O.S. Selections Inc. v. United States, decided 6-3 in February 2026, the Supreme Court ruled that IEEPA does not grant the President authority to impose sweeping tariffs on imports outside of a genuine national security emergency involving armed conflict or equivalent crisis. The majority opinion, authored by Chief Justice Roberts, held that Congress did not delegate such broad tariff-setting power through IEEPA's general emergency language. As a result, all IEEPA reciprocal tariffs collected between February 4, 2025 and the ruling date were deemed unlawfully collected and must be refunded.

Within days of the ruling, the administration invoked Section 122 of the Trade Act of 1974, which allows the President to impose a temporary 15% tariff (or up to 15% on any one country) for a period not to exceed 150 days when a "large and serious" balance-of-payments deficit exists. The Section 122 rate was set at 10% universally. It is constitutionally distinct from IEEPA and legally defensible on its own terms. However, Section 122 tariffs expire automatically at the 150-day mark (around July 24, 2026) unless Congress acts.

CAPE stands for Customs Automated Post-Entry, the CBP system through which importers can submit post-entry claims including refund requests for unlawfully collected duties. CBP opened the CAPE portal to IEEPA refund claims on April 20, 2026. Importers log in through their existing ACE (Automated Commercial Environment) credentials, upload a structured CSV file containing entry summaries, and CBP processes each line item. Approved refunds are issued to the bank account on file via ACH transfer.

CBP has not published a firm SLA, but industry practitioners estimate 60 to 90 days from submission for straightforward claims. Complex entries, discrepancies between the CSV and the underlying 7501 data, or entries flagged for manual review can extend processing to 120 days or more. CBP processes claims in batches, and early filers who submitted clean, accurate data have generally moved through the queue faster.

The calculator multiplies your reported import value by the IEEPA reciprocal rate for your selected country. It then adds a 5% estimated statutory interest component, which CBP may apply to unlawfully collected duties under 19 U.S.C. § 1505. The result is a rough estimate — your actual refund depends on the precise dutiable value CBP used on each 7501 entry, any applicable exclusions, and whether interest is ultimately awarded. CBP calculates refunds on an entry-by-entry basis from your actual filed paperwork, not a blended rate against a total.

The estimate is directionally useful but should not be relied upon for accounting or financing decisions. Actual refunds may be higher or lower. Common reasons an actual refund differs from the estimate: (1) some entries were excluded or partially excluded, (2) USMCA or FTA treatment applied to some line items, (3) the reported import value includes freight and insurance that may or may not have been included in CBP's dutiable value calculation, (4) some goods may have been entered under different HTS codes than expected.

Potentially. Under 19 U.S.C. § 1505, CBP may owe interest on duties that were unlawfully collected, calculated at the Treasury rate in effect at the time of the original payment. Whether interest will be awarded in CAPE refunds is still being determined through the CIT order, and CBP has not yet publicly committed to paying interest on all claims. We include a 5% interest estimate in the calculator as a placeholder — treat it as a possible upside, not a guaranteed component.

You will need: (1) ACE portal access with your Importer of Record credentials, (2) all CBP Form 7501 entry summaries covering the IEEPA duty period, (3) your ACH banking information registered in ACE for the refund deposit, (4) a properly formatted CSV file with one row per entry line containing: entry number, entry date, HTS code, country of origin, dutiable value, IEEPA duty rate, and duty amount paid. CBP has published a CSV template on the CAPE portal.

ACE (Automated Commercial Environment) is CBP's primary import and export processing platform. To register, visit ACE.CBP.gov and request an importer account using your EIN (Employer Identification Number) or SSN for sole proprietors. New account approvals can take 5 to 10 business days. If you previously imported through a licensed customs broker, your broker may already have your importer data in ACE — ask them to provide you with access credentials or to file on your behalf.

The CAPE CSV format as of April 2026 has a 9,999-row limit per submission. Importers with more than 9,999 entry lines must split their claim into multiple CSV submissions. CBP has indicated it will accept multiple submissions per importer, but has not published a maximum number of total submissions.

No — any importer of record can file directly through CAPE using their own ACE credentials. However, licensed customs brokers can file on your behalf if they hold a valid power of attorney for your imports. Importers with large entry volumes, complex HTS code situations, or limited ACE experience often find it cost-effective to work with a broker or a specialized recovery partner to prepare and submit the claim. Our vetted recovery partner can handle the entire filing for you.

The CIT order establishing the right to IEEPA refunds included a filing deadline for claims. As of April 2026, that deadline has not been publicly specified beyond the CAPE portal launch date. However, CBP typically applies a 4-year statute of limitations on duty drawback claims (19 U.S.C. § 1313). We recommend filing as early as possible — waiting until close to any deadline increases the risk of processing errors, queue backlogs, and potentially missing the refund window entirely.

This is a nuanced area that you must discuss with a licensed CPA or tax attorney. As a general principle, if the original tariff payments were deducted as a business expense or included in the cost of goods sold, the refund likely creates taxable income in the year received. If the tariffs were capitalized into inventory and not yet sold, the tax treatment is more complex. We are not tax advisors — consult a licensed professional before making any accounting decisions based on anticipated refunds.

Recovery partners typically charge either a flat fee or a contingency fee (a percentage of the refund recovered). Contingency fees in the market range from 10% to 30% depending on claim complexity and volume. Flat fees vary widely. Our vetted recovery partner will provide a free assessment and quote before you commit. Using a partner costs money but reduces your internal time investment and may improve accuracy, especially for high-volume filers.

There is no legal minimum — CBP will process any valid CAPE claim. However, from a practical standpoint, the time required to gather documents, format the CSV, and manage the ACE portal process makes very small claims (under $500) potentially not worth the effort for a DIY approach. If you use a recovery partner, they will assess whether the claim size justifies their fees. Some partners have minimums; others accept all claim sizes.

CBP deposits approved refunds via ACH directly to the bank account registered in your ACE importer profile. You must have ACH banking information on file before or during the CAPE submission. Wire transfers and checks are not used. Ensure your ACE banking information is current and matches the account you want the refund deposited into — CBP will not redirect funds after processing.

DIY is appropriate if: you have 50 or fewer entries, you are comfortable with ACE, your entries are simple (single country, single HTS code class, no FTA complications), and you have time to prepare the CSV carefully. A recovery partner is worth considering if: you have hundreds or thousands of entries, your imports span multiple countries or complex HTS classifications, you lack ACE experience, or you want to maximize accuracy and minimize the risk of a rejected or reduced claim.

Based on early CAPE filers, the most common errors include: (1) incorrect entry numbers that don't match CBP records, (2) mismatched dutiable values that differ from the 7501 data on file, (3) claiming duties for FTA-exempt entries, (4) CSV formatting errors (wrong delimiter, missing columns, extra header rows), (5) submitting before ACH banking is registered in ACE, and (6) using an importer EIN that differs from the one on the original 7501s.

Yes. A licensed customs broker holding a valid power of attorney (CBP Form 5291 or equivalent) can submit CAPE claims using their own ACE access under your importer of record number. This is the standard practice and does not require you to share your own ACE login. Confirm with your broker that their POA is current and covers post-entry filings before proceeding.

Some specialty finance firms and trade finance providers are offering receivable monetization against approved or filed CAPE claims. Terms vary widely. This is an advanced financial instrument — the refund receivable must be validated, the financing provider takes on collection risk, and fees can be substantial. We do not recommend monetizing an unvalidated estimate; wait until you have a filed, acknowledged CAPE claim before exploring this option, and consult a financial advisor.

CBP will issue an explanation for any rejected or reduced claim. Common rejection reasons include: claim for entries already processed, mismatch between filed data and CBP records, and ineligible goods or entry types. You generally have the right to protest a CBP decision under 19 U.S.C. § 1514 within 180 days of the decision. Consult a licensed customs broker or trade attorney if your claim is rejected, especially for large claim amounts.