Do You Qualify for an IEEPA Tariff Refund?
IEEPA tariff refunds are available to U.S. importers who paid IEEPA-imposed duties between early 2025 and early 2026. Use this checklist to assess whether your business may qualify for Phase 1 claims through the CAPE portal.
Eligibility Checklist
Work through each item below. The more boxes you can check, the stronger your likely eligibility for a Phase 1 IEEPA tariff refund. Each item links to a more detailed explanation.
Did you import goods into the U.S. between February 2025 and February 2026?
Phase 1 of the CAPE portal covers entries where IEEPA duties were paid during the period the tariffs were in effect. The tariffs were imposed beginning in early 2025 and struck down by the Supreme Court on February 20, 2026.
Learn more: IEEPA tariff timeline → Are you the Importer of Record (Box 26 of CBP Form 7501)?
Only the importer of record can file a CAPE claim directly. If a customs broker or 3PL filed as the IOR on your entries, you will need their cooperation or authorization to claim a refund.
Learn more: What is an importer of record? → Did your entries include HTS Chapter 99 IEEPA codes (9903.01.xx)?
IEEPA tariffs were tracked in the customs system using special HTS Chapter 99 codes with the 9903.01.xx prefix. These codes appear on CBP Form 7501 and your ACE entry records. Section 301, 232, and 122 tariffs use different codes and are not covered by CAPE Phase 1.
Learn more: IEEPA tariff codes reference → Do you have an ACE Portal account with ACH banking configured?
The CAPE portal is a module within CBP's Automated Commercial Environment (ACE). You need an existing ACE account, and your ACH direct deposit banking profile must be set up in ACE before you can receive a refund. Refunds are not issued by paper check.
Learn more: ACE portal setup guide → Are your entries unliquidated, or were they liquidated within the last 80 days?
Phase 1 covers entries that are either still unliquidated (CBP has not yet issued a final duty assessment) or that were liquidated within the 80-day protest window. Entries liquidated more than 80 days ago require a protest filing, which will be addressed in a future phase.
Learn more: Phase 1 vs. future phases →Ready to check your actual entries?
A recovery partner can review your import records and tell you exactly how much you may be owed — at no upfront cost. You only pay if a refund is recovered.
Check if you qualifyPhase 1 vs. Future Phases
| Entry Type | Phase | Status |
|---|---|---|
| Unliquidated IEEPA entries | Phase 1 | Open now |
| Entries liquidated within 80 days | Phase 1 | Open now |
| Protested entries | Phase 2 | TBD |
| Entries liquidated > 80 days ago (no protest) | Phase 2/3 | TBD |
| AD/CVD affected entries | Future phase | TBD |
| Duty drawback interactions | Future phase | TBD |
Source: CBP CAPE framework, March 12, 2026. Future phase timelines have not been announced. Full phase breakdown →
Tariff Types: What Qualifies vs. What Doesn't
Eligible Tariffs (IEEPA)
- Canada and Mexico IEEPA tariffs (early 2025)
- China IEEPA escalation tariffs (throughout 2025)
- "Reciprocal" IEEPA tariffs on other trading partners
- Any tariff tracked under HTS 9903.01.xx codes
Not Eligible (Different Authority)
- Section 301 tariffs on Chinese goods (9903.88.xx)
- Section 232 steel and aluminum tariffs
- Section 122 balance-of-payments tariffs
- Standard MFN (most favored nation) duties
- Antidumping / countervailing duties
Still not sure if you qualify?
A recovery specialist can review your actual import records at no upfront cost.
Check if you qualify