A refund smaller than expected is common, and it is not always an error. The IEEPA refund returns IEEPA duties only. Many 2025 entries carried several kinds of duty at once.
Expected gaps
- Section 232 duties on steel, aluminum, autos, auto parts, and other products are not part of the IEEPA refund.
- Section 301 duties, including many on goods from China, are not part of it either.
- Metal content. From June 4, 2025, derivative steel and aluminum products paid Section 232 duty on the metal content and the IEEPA reciprocal tariff on the rest of the value. Only the IEEPA portion comes back.
Gaps worth checking
- Entries missing from your CAPE declaration, or rejected and not resubmitted
- Entries of a type CAPE does not yet accept
- Offsets against other amounts owed to CBP
- Interest missing from the refund; CBP says interest is calculated under 19 CFR 24.36
- Errors in how the metal content split was reported at entry
How to check
Compare, entry by entry, the IEEPA duty paid (ES-003) with the principal and interest refunded (ES-022). Our paid short page has an example layout, and our ACE reports guide shows where to find each report.
What this means for importers
Start by separating expected gaps from unexplained ones. Only the unexplained ones are worth a broker's time, and a clear comparison makes that conversation short.
General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.
Sources
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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.