IEEPA tariff refund still not resolved? Find out where it stands.
Approved but unpaid, never filed, denied, short, excluded, or told it is too late. Answer 3 quick questions. We explain your general options in plain English and email you a list of licensed customs brokers and attorneys who handle your situation.
Question 1 of 3
- Free for importers, with no obligation
- Your general options in plain English, with sources
- A list of licensed customs brokers and attorneys who handle your situation
- You choose who to contact. We do not file with CBP or give legal advice
Does one of these sound familiar?
Refunds are flowing. As of September 11, 2026, CBP had accepted about $134.7 billion in IEEPA refund requests and sent about $122 billion to the Treasury for payment. But not every importer's refund goes through cleanly, and each situation has its own rules and deadlines.
Figures from a CBP declaration filed in the Court of International Trade, as reported by Supply Chain Dive and Mohawk Global.
Approved but not paid yet
CBP says refunds usually arrive 60 to 90 days after acceptance. Delays often trace to ACH refund setup. The REV-603 report in ACE shows where each refund stands.
What to check →Never filed, or not sure
CAPE covers unliquidated entries and entries within 80 days of liquidation. The first step is finding out which entries were paid and where each one stands.
Where to start →Missed CAPE, maybe not too late
Once an entry is more than 80 days past liquidation, CAPE Phases 1 and 2 no longer cover it. A protest is generally due within 180 days of liquidation.
The protest window →Finally liquidated, or told it is too late
CBP says it needs a court order to refund finally liquidated entries. July 2026 court orders cover importers who sued, and new lawsuits have their own deadline.
Where this stands →Entries excluded from CAPE
AD/CVD, some foreign trade zone, warehouse, drawback, informal, and Section 321 entries fall outside CAPE or follow special rules. CBP says more guidance is coming for some.
By entry type →Paid short, or interest looks wrong
IEEPA duties mixed with Section 232 or 301 duties, entries missing from the claim, or interest you cannot find. The ES-022 report shows principal and interest separately.
Find the gap →Claim or protest denied
Many CAPE rejections are data errors that can be corrected and refiled. A denied protest generally leads to the Court of International Trade, with a 180-day window.
Denials explained →Not sure you were the importer
If you bought DDP, or a broker, seller, or supplier was the importer, CBP pays the refund to them, not you. You may have contract options with the seller. That is a question for an attorney.
If you were not the IOR →Brokers, CPAs, and forwarders
Have clients with stuck refunds? Point them to our free guides or have them contact us. We do not file with CBP, and importers never pay us.
For professionals →How it works
We are an information and connection service. We help you understand where your refund stands and who can help, and you decide what to do next.
Tell us your situation
Answer three questions. A team member follows up within one business day (Mon-Fri 9-5 PT).
Understand your options
We explain the general options for your situation in plain English, with sources, including the deadlines to raise with a professional.
Get a list of professionals
We email you a list of licensed customs brokers and attorneys who handle your type of situation.
You choose
You contact any of them directly, or none. Any engagement and fee is between you and that professional.
You or your current broker
Many CAPE filings and simple corrections can be handled by you in ACE, or by the customs broker you already use. Importers can file with CBP at no cost. Our free guides show how to pull the reports.
Broker-prepared filings
Protests, corrections, and other filings prepared for you must be done by a licensed customs broker. If you do not have one, we email you a list. The broker contracts with you and bills you directly.
Legal questions and court deadlines
Denied protests, finally liquidated entries, lawsuits, and contract claims against a seller are legal matters. We email you a list of attorneys who handle them, and you contact them directly.
Free tools
Run the numbers yourself first. Nothing you enter leaves your browser.
What we do, and what we don't
We keep a clear line between general information and licensed work. That protects your refund and keeps you away from the refund scams CBP has warned importers about.
We do
- Explain the general options for your situation in plain English, with sources
- Show you how to pull your own ACE reports, such as ES-003, ES-022, and REV-603
- Point out the general deadlines to raise with a professional
- Email you a list of licensed customs brokers and attorneys who handle your situation
- Keep our guides free and up to date
We don't
- Charge importers anything
- Prepare or file CAPE declarations, corrections, or protests
- Give legal or customs advice, or represent you before CBP or any court
- Ask for your ACE login, bank details, or Social Security number
- Receive your refund. CBP pays the Importer of Record directly
- Sell your information
How we are paid
Importers never pay us. Law firms and customs brokers do not pay us per referral, per client, or a share of any fee or refund. If we offer paid listings in our professional directory in the future, they will be flat-fee and clearly labeled, and you will always choose who to contact. We do not sell your personal information.
We are not a law firm, not a licensed customs broker, and not affiliated with U.S. Customs and Border Protection or any government agency.
Why timing matters
Each entry runs on its own clock. Select a point on the timeline to see what it means and where the rule comes from. These are general windows; confirm your own dates with a licensed customs broker or attorney.
Entry filed and IEEPA duties paid
IEEPA duties were deposited with CBP when the entry was filed. Refunds go only to the Importer of Record. Some practitioners count the two-year lawsuit clock from this date.
Source: Troutman Pepper Locke, Aug 2026
Liquidation
Liquidation is CBP's final calculation of the duty owed. It usually happens within about a year, and an entry not liquidated within one year is deemed liquidated. Unliquidated entries can go through CAPE.
Source: 19 U.S.C. 1504
CAPE window: 80 days after liquidation
CAPE Phases 1 and 2 cover unliquidated entries and entries within 80 days of liquidation. CBP has not set a closing date for CAPE itself, but each entry leaves the window 80 days after it liquidates.
Source: CBP CSMS #68340863
Protest: 180 days after liquidation
A protest is generally due within 180 days after an entry liquidates. If no protest is filed, the liquidation becomes final. Finally liquidated entries are outside CAPE Phases 1 and 2.
Source: 19 U.S.C. 1514
After a denied protest: 180 days
If CBP denies a protest, a lawsuit in the U.S. Court of International Trade is generally due within 180 days after CBP mails the denial.
Source: 28 U.S.C. 2636(a)
Separate route: the two-year lawsuit
Suits under 28 U.S.C. 1581(i) must be filed within two years after the claim accrues. Practitioners disagree on when that clock starts. Some count from the date duties were paid, which would put the earliest deadlines around February 2027.
Sources: 28 U.S.C. 2636(i); Troutman Pepper Locke, Aug 2026; Barnes & Thornburg, Sep 2026
Where finally liquidated entries stand
CBP says it cannot refund finally liquidated entries without a court order. July 2026 court orders direct refunds for importers who sued, and CAPE Phase 3 for them is scheduled for October 6, 2026. The government's appeal and a request to certify a class of importers are pending.
Sources: Holland & Knight, Jul 2026; Supply Chain Dive, Sep 2026
General information; confirm your dates with a licensed professional. Last reviewed: September 24, 2026.
Common questions
Short answers, with links to CBP's own guidance, the law, and our detailed guides.
What happened to the IEEPA tariffs?
On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act does not authorize tariffs. You can read the Supreme Court opinion or our plain-English explainer.
Who can receive an IEEPA tariff refund?
Only the Importer of Record, the party that paid the duties to CBP, or a party it designated on CBP Form 4811. If you bought goods delivered duty paid (DDP), or a broker, seller, or supplier acted as the importer, the refund goes to them. See if you were not the Importer of Record.
Are Section 232 and Section 301 duties refunded too?
No. The Supreme Court ruling covered tariffs imposed under IEEPA. Section 232 duties (such as steel, aluminum, autos, and auto parts) and Section 301 duties are separate and are not part of the IEEPA refund. This is the most common reason a refund looks smaller than expected.
What is CAPE?
CAPE (Consolidated Administration and Processing of Entries) is the tool CBP built in the ACE Portal to process IEEPA refunds in bulk. It opened April 20, 2026. CBP's instructions are in its CSMS messages to the trade. Our phase-by-phase guide explains it in plain English.
Where can I read CBP's official guidance?
CBP publishes IEEPA refund instructions through its Cargo Systems Messaging Service (CSMS), including the announcement of CAPE, Phase 1 instructions, and refund tracking reports. CBP also maintains an IEEPA duty refunds page. Technical questions can go to IEEPARefunds@cbp.dhs.gov.
My refund was approved but I have not been paid. What should I check?
CBP says refunds are generally issued 60 to 90 days after a CAPE declaration is accepted. Refunds are paid only by ACH, so the Importer of Record, or its Form 4811 designee, must be set up for ACH refunds. The REV-603 report in ACE shows each refund's status. See approved but not paid.
I never filed anything. Is it too late?
Not necessarily. CAPE covers unliquidated entries and entries within 80 days of liquidation, and CBP has not set a closing date for CAPE itself. Each entry leaves the window 80 days after it liquidates, so the first step is finding out where each entry stands. See never filed or not sure.
Can I file the CAPE declaration or a protest myself?
Yes. CBP accepts CAPE declarations from the Importer of Record or the broker that filed the entries, and importers can file directly with CBP at no cost. Filings prepared for you by someone else must be prepared by a licensed customs broker.
How do I find which of my entries had IEEPA duties?
Run the ES-003 report in ACE and filter on the IEEPA tariff numbers 9903.01.xx and 9903.02.xx. Your customs broker can also pull it for you. See our ACE reports guide.
What if my entries are AD/CVD, foreign trade zone, warehouse, or drawback entries?
Several entry types were excluded from CAPE or follow special rules. Warehouse withdrawals are now accepted instead of warehouse entries, and FTZ entries only when flagged for reconciliation. AD/CVD, drawback, informal, and Section 321 entries have no CAPE route yet. See excluded entry types.
My entries are finally liquidated. Is it too late?
Not necessarily, but CBP says it cannot refund finally liquidated entries without a court order. Court orders issued in July 2026 direct refunds for importers who sued, and the government has appealed related orders. A separate two-year deadline applies to new lawsuits. Talk to a trade attorney promptly. See finally liquidated entries.
What is the deadline to file a protest?
A protest is generally due within 180 days after an entry liquidates, under 19 U.S.C. 1514. If no protest is filed, the liquidation becomes final. Confirm your dates with a licensed customs broker or attorney.
Are you a law firm or a customs broker?
No. TariffClarity is an information and connection service operated by TariffClarity LLC. We explain general options in plain English and, when your situation needs a licensed customs broker or an attorney, we email you a list of professionals who handle it. You contact them directly and work with them under their own engagement terms.
What does it cost, and how are you paid?
Importers never pay us. Law firms and customs brokers do not pay us per referral, per client, or a share of any fee or refund. If we offer paid listings in our professional directory in the future, they will be flat-fee and clearly labeled. Any broker or attorney you choose sets its own fees in its own written agreement with you.
Will you ever ask for my bank or ACE login details?
No. Refunds go from the government to the Importer of Record by ACH. CBP has warned importers about refund scams, and anyone asking for your ACE credentials or banking details to "process" your refund should be treated as a red flag. Suspected fraud can be reported to IEEPAFraud@cbp.dhs.gov.
How much does help with an IEEPA refund cost?
It varies. Brokers often charge per entry, a percentage, or both; law firms may use contingency, fixed, hourly, or blended fees. You can also file in CAPE yourself through ACE. Get every fee in writing. See what refund help costs.
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