IEEPA Tariff Refund: Frequently Asked Questions

U.S. importers who (1) paid IEEPA tariff surcharges on goods imported between February 2025 and February 20, 2026, (2) were listed as the Importer of Record (Box 26 of CBP Form 7501), and (3) have entries that are either unliquidated or liquidated within the past 80 days. See our full eligibility checklist for details.

Yes. There is no minimum size requirement. If your small business imported goods from China, Canada, Mexico, or another IEEPA-affected country and paid IEEPA tariff surcharges, you may qualify. The challenge for smaller businesses is often the administrative work of retrieving entry records and preparing the CAPE CSV — a customs broker can help with this.

The Importer of Record is the legal entity responsible for ensuring goods comply with U.S. customs law and for paying associated duties. It appears in Box 26 of CBP Form 7501. Only the IOR — or an authorized agent filing on their behalf — can submit a CAPE refund claim. Learn more about IOR.

Yes, but you will need to coordinate with your broker. When a broker was listed as IOR, the broker holds the formal refund right. You can ask the broker to file on your behalf and pass through the refund, or a customs attorney can structure an assignment of the refund claim from the broker to you.

No. Section 301 tariffs (tracked under HTS codes 9903.88.xx) were imposed under the Trade Act of 1974, not under IEEPA. The Supreme Court's ruling in Learning Resources v. Trump invalidated only IEEPA tariffs — Section 301 tariffs are not part of the CAPE refund program and remain in effect.

No. Section 232 tariffs are national security tariffs imposed under the Trade Expansion Act of 1962, not IEEPA. They are not part of the CAPE refund program. If your entries show both 9903.80.xx (Section 232) and 9903.01.xx (IEEPA) codes, only the IEEPA portion is refundable.

Generally, no — not directly through the CAPE portal. The refund program is available to importers of record, which are typically businesses, not individual consumers. However, class action lawsuits have been filed against retailers who separately charged customers IEEPA tariff surcharges, seeking to have those amounts passed back to consumers. Those cases are ongoing.

If you are the Importer of Record and have ACE portal access, you can file the CAPE claim yourself. However, most importers find working with a customs broker or recovery specialist more efficient, particularly for assembling entry records in the correct format. Self-filing is most practical if you have a small number of entries and existing ACE familiarity.

IEEPA stands for the International Emergency Economic Powers Act, a 1977 federal law. The Trump administration used IEEPA to impose tariffs on goods from China, Canada, Mexico, and other countries beginning in early 2025 — the first time IEEPA had ever been used to impose tariffs. The Supreme Court ruled in February 2026 that IEEPA does not authorize tariff imposition. Full explanation →

The first IEEPA tariffs took effect February 4, 2025, imposing 25% duties on Canadian and Mexican goods. China-specific IEEPA tariffs followed in February 2025 and escalated through June 2025. "Reciprocal" tariffs on dozens of other trading partners began in April 2025. See the full timeline →

Canada, Mexico, China, and approximately 180 other trading partners were subject to IEEPA tariffs at various points during 2025. China faced the highest rates (up to 125% additional IEEPA duty). Canada and Mexico faced 25% (10% for Canadian energy). Many other countries faced "reciprocal" rates ranging from 10-49%. Country-by-country breakdown →

IEEPA tariffs were tracked using HTS Chapter 99 codes starting with 9903.01.xx. Common codes include 9903.01.01 (Canada general, 25%), 9903.01.03 (Mexico, 25%), and 9903.01.10 through 9903.01.14 (China, escalating rates). Full code reference →

The Supreme Court held 6-3 in Learning Resources, Inc. v. Trump (February 20, 2026) that IEEPA does not authorize the president to impose tariffs. The majority found that IEEPA's authority to "regulate" foreign commerce does not include the power to tax it through import duties, applying the major questions doctrine to require clear congressional authorization for such a vast grant of taxing power. Full ruling explanation →

Yes — our complete IEEPA tariff list covers every executive order imposing tariffs, organized chronologically by date, country, rate, and HTS Chapter 99 code.

CBP has estimated a 60-to-90-day processing timeline from CAPE claim submission to ACH refund disbursement for Phase 1. Actual timelines may vary based on claim volume, the complexity of your entries, and whether any issues arise during CBP's recalculation step. Interest accrues during the processing period.

CAPE stands for Customs Automated Processing Environment. It is a module within CBP's existing ACE (Automated Commercial Environment) portal through which importers submit IEEPA tariff refund declarations. CAPE launched April 20, 2026. Full CAPE walkthrough →

Phase 1 (open now) covers unliquidated entries and entries liquidated within the past 80 days. Future phases (not yet launched) will address entries with pending protests, older liquidated entries, antidumping/countervailing duty interactions, and drawback claims. Full phase breakdown →

For entries liquidated within the past 80 days, CBP will issue a reliquidation — correcting the original liquidation to remove IEEPA duties. Entries liquidated more than 80 days ago (without a pending protest) fall outside Phase 1 and will be addressed in future CAPE phases.

The Supreme Court's ruling is final — there is no higher court to appeal to. The refund obligation is established by the Court's ruling and the CIT's reliquidation order. The administration may pursue alternative tariff authorities (Section 301, Section 232, or new legislation) for future trade barriers, but these would apply prospectively and would not affect existing IEEPA refund rights.

Potentially yes. If your business previously deducted IEEPA tariff payments as a business expense, the refund of those amounts is generally taxable income in the year received under the tax benefit rule. The statutory interest component is also typically taxable. IRS guidance specific to IEEPA refunds has not yet been issued. Full tax implications guide →

Not necessarily, unless your agreements or invoices explicitly promised to pass through tariff adjustments. However, if you separately itemized IEEPA tariff surcharges on customer invoices or receipts, you may face class action exposure from customers seeking the return of those amounts. Consult a lawyer if this applies to your business.

Yes — this is called receivable monetization. Specialty finance firms and hedge funds offer to advance 50-80% of your expected refund in exchange for the right to receive the CBP payment when it arrives. Full monetization guide →

It depends on your volume and complexity. Self-filing is reasonable for small importers with a clean single-broker situation and modest expected refunds. For large refunds, complex IOR situations, or high entry volumes, a recovery partner typically produces better and faster results. Full comparison guide →

Most recovery specialists work on contingency — typically 15-30% of the recovered refund amount. There is usually no upfront cost, and you pay nothing if nothing is recovered. Some firms also offer flat-fee preparation services for simpler claims.

A format rejection (malformed CSV, encoding issues, header mismatch) allows you to correct and refile — but the 60-to-90-day clock restarts with your corrected submission. A substantive rejection (wrong IOR, ineligible entries, amount discrepancy) requires resolution with CBP directly, which can take additional weeks. Common mistakes to avoid →