Common reasons for a gap
- Stacked duties. Only IEEPA duties are refunded. Section 232 and Section 301 duties paid on the same entries are not part of the refund. If they were in your estimate, the gap may be expected.
- Steel and aluminum content. From June 4, 2025, derivative products paid Section 232 duties on their metal content and the IEEPA reciprocal tariff on the rest of the value. Errors in how that split was reported flow into the refund.
- Entries left out. Entries missing from your CAPE declaration, entries rejected and not resubmitted, or entry types CAPE does not yet accept.
- Offsets. CBP can apply a refund against other amounts the importer owes.
- Interest. CBP says interest is calculated on these refunds under 19 CFR 24.36. Check that it was included.
How to find the gap
Line up three numbers for each entry: IEEPA duties paid, principal refunded, and interest refunded. The ES-003 report shows the IEEPA duty lines, and the ES-022 report shows principal and interest for entries in your CAPE declarations. See our ACE reports guide.
An example layout
This example uses made-up numbers to show how to lay out a comparison. It is not based on any real importer.
| Entry | IEEPA duty paid | Principal refunded | Interest refunded | What to ask |
|---|---|---|---|---|
| Example A | $10,000 | $10,000 | Shown | Nothing; matches |
| Example B | $8,000 | $5,000 | Shown | Was part of the duty Section 232 or 301, or a metal-content split? |
| Example C | $6,000 | $0 | None | Was the entry in the declaration? Rejected? Excluded type? |
| Example D | $4,000 | $4,000 | None shown | Why is interest missing? Ask your broker or CBP. |
If the gap is not explained by duty type, a licensed customs broker can look at the entries with you. We can email you a list.
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.