Tariff Refund Questions and Answers

Straight answers to the questions importers ask most.

Basics

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.

Filing and refund status

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.

Is interest paid on IEEPA refunds?

CBP says interest is calculated on these refunds as on other interest-eligible refunds, under 19 CFR 24.36. The ES-022 report in ACE shows principal and interest separately. See interest on IEEPA refunds.

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.

What records are useful to have?

Any rejection or short-payment notice, entry numbers or entry summaries (CBP Form 7501), any protest and decision, and refunds received. The ES-003, ES-022, and REV-603 reports in ACE cover most of this. You never share your login with us.

Can I estimate my refund?

Yes. Our free refund estimator gives a rough estimate of IEEPA duty from entered value, origin, and entry date. Your ACE ES-003 report shows the IEEPA duty actually paid.

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.

What is the deadline to sue in the Court of International Trade?

After a protest is denied, a suit is generally due within 180 days. Suits under the court's residual jurisdiction, 28 U.S.C. 1581(i), must be filed within two years after the claim accrues, and practitioners disagree on when that clock starts. See 28 U.S.C. 2636 and our two-year deadline guide.

What is CAPE Phase 3?

CBP has scheduled Phase 3 for October 6, 2026. It covers finally liquidated entries of importers who sued, whose reliquidation the court has ordered, and who gave CBP a valid importer number by July 30, 2026. See our news item.

Do I have to share my refund with customers I charged a tariff surcharge?

No federal statute requires it, but customers have filed lawsuits, and contracts may give business customers a claim. Talk to an attorney. See passing refunds to customers.

About TariffClarity

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.

What happens when you send me a list of professionals?

We email you the names and contact details of licensed customs brokers or attorneys who handle your type of situation. You decide whether to contact any of them. We do not follow up with them for you, and we do not send them your information unless you ask us to.

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 do I check that a customs broker or attorney is licensed?

Ask for the broker's CBP license number or the attorney's bar number and state, then check it. CBP explains how to check a broker license, and each state bar has a public lookup. See our verification guide.

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.

General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.

General information, not legal advice. Tariff refund rules and court rulings are changing. Deadlines depend on your own entries. Confirm your options with a licensed customs broker or attorney. TariffClarity is not a law firm or customs broker.

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