IEEPA Tariff Refunds: What They Are and How to Claim Yours

IEEPA tariff refunds are repayments of import duties that were unlawfully collected by the U.S. government between early 2025 and February 2026. The refunds exist because the Supreme Court ruled that the tariffs were imposed without legal authority — meaning the government collected money it had no right to collect, and must now return it.

This guide explains what IEEPA tariff refunds are, who qualifies to receive them, how much is available, and how the claim process works.

What Are IEEPA Tariff Refunds?

IEEPA tariff refunds are government-issued repayments to U.S. importers who paid tariff surcharges under the International Emergency Economic Powers Act (IEEPA) between February 2025 and February 20, 2026.

During that period, the Trump administration used IEEPA authority to impose sweeping tariffs on goods from China, Canada, Mexico, and roughly 180 other trading partners. These tariffs were added on top of ordinary customs duties, significantly increasing the landed cost of imported goods across virtually every product category.

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that IEEPA does not give the president authority to impose tariffs. The ruling declared the tariffs unlawfully imposed from the outset — not merely impermissible going forward. That legal posture is what creates the refund right: if the duties were collected without legal authority, the government holds those funds without justification and must return them.

The U.S. Court of International Trade followed up with a reliquidation order in March 2026, directing U.S. Customs and Border Protection (CBP) to establish a refund mechanism. CBP launched the CAPE (Customs Automated Processing Environment) portal on April 20, 2026, to process Phase 1 claims.

For more background on the legal history, see our guide on what IEEPA is and the Supreme Court ruling explained.

How Much in IEEPA Tariff Refunds Is Available?

CBP estimates approximately $166 billion in IEEPA tariff refunds owed to U.S. importers across an estimated 330,000 affected businesses. That figure represents the aggregate of all IEEPA surcharges collected during the roughly 12-month period the tariffs were in effect.

Individual refund amounts vary enormously based on:

• Import volume — how many shipments you received during the IEEPA period
• Country of origin — Chinese goods faced the highest IEEPA rates (up to 125%); Canadian and Mexican goods faced 25%
• Product category — high-value products like electronics and industrial equipment generate larger per-entry refunds than low-cost consumer goods
• Timing — imports during peak IEEPA escalation periods (May–February 2026) carry the highest refundable amounts

Smaller importers might recover thousands of dollars; large importers with high-volume Chinese sourcing may have claims in the millions.

Refunds also include statutory interest accruing from the original duty payment date. Interest accumulates in your favor during the CBP processing period and is included automatically in the refund calculation — you do not need to claim it separately.

Who Qualifies for IEEPA Tariff Refunds?

To qualify for a Phase 1 IEEPA tariff refund, you generally need to meet all of the following criteria:

1. You imported goods between February 2025 and February 2026 Specifically, your entries must have included HTS Chapter 99 codes in the 9903.01.xx range — the codes CBP used to track IEEPA tariff surcharges. See our IEEPA tariff codes guide to identify which codes apply to your entries.

2. You are the Importer of Record (IOR) Only the entity listed in Box 26 of CBP Form 7501 can file a CAPE claim directly. If a customs broker or freight forwarder was the IOR on your entries, you will need to coordinate with them.

3. Your entries are within Phase 1 scope Phase 1 of the CAPE portal covers:

• Entries that are currently unliquidated (CBP has not yet finalized the duty assessment)
• Entries that were liquidated within the past 80 days

Older liquidated entries will be addressed in future CAPE phases.

4. You have ACE portal access with ACH banking configured The CAPE portal is a module within CBP’s Automated Commercial Environment. You need an active ACE account and a verified ACH banking profile to receive the refund via direct deposit.

For a detailed eligibility walkthrough, see our eligibility checklist.

What Tariffs Are NOT Refundable?

Not all tariffs paid in 2025–2026 are part of the IEEPA refund program. Specifically excluded:

• Section 301 tariffs on Chinese goods (HTS codes 9903.88.xx) — these were imposed under the Trade Act of 1974 and were not challenged in the IEEPA case
• Section 232 steel and aluminum tariffs (HTS codes 9903.80.xx) — imposed under national security authority
• Ordinary MFN (most-favored-nation) duties — standard tariff rates that apply regardless of IEEPA

Only the IEEPA surcharge portion (the 9903.01.xx amounts) of your duty payments is refundable. If your entries included both Section 301 duties and IEEPA surcharges, you can recover the IEEPA portion but not the Section 301 portion.

How the IEEPA Tariff Refund Process Works

The refund process runs through CBP’s CAPE portal and follows these four steps:

Step 1 — Identify your eligible entries Pull your entry records from ACE (or request them from your customs broker) for the period February 2025 through February 2026. Look for entries with IEEPA Chapter 99 codes (9903.01.xx).

Step 2 — Prepare your CAPE declaration Assemble a CSV file in CBP’s published CAPE format listing each eligible entry line with entry numbers, IEEPA codes, and IEEPA duty amounts. The format is strict — errors cause rejection. See our CAPE portal guide and common mistakes guide before submitting.

Step 3 — Submit through the CAPE portal Upload your declaration through the CAPE module in your ACE portal account. CBP will send a confirmation number. Processing takes 60 to 90 days for Phase 1.

Step 4 — Receive your refund via ACH After CBP approves your claim and reliquidates your entries, the refund is disbursed directly to your ACE-linked bank account. Statutory interest is included in the disbursement.

DIY Filing vs. Working with a Recovery Partner

You have two paths to filing an IEEPA tariff refund:

Self-filing makes sense if you have a small number of entries, a single customs broker, and in-house customs compliance experience. The CAPE CSV format requires precision — see our common filing mistakes guide to avoid the most frequent rejection causes.

Recovery partners are specialists (customs brokers, duty drawback firms, trade attorneys) who prepare and file CAPE claims on a contingency basis — typically 15–30% of the recovered amount. For importers with large refund claims, complex IOR situations, or high entry volumes, the fee is usually justified by faster and more accurate results.

For a full comparison, see our DIY vs. expert help guide.

Timeline: When Will You Receive Your Refund?

• Now: CAPE Phase 1 is open and accepting claims
• 60–90 days after filing: Expected CBP refund disbursement for Phase 1 (unliquidated and recently liquidated entries)
• Future phases: Entries with older liquidation dates, pending protests, and complex duty situations will be addressed in subsequent CAPE phases (timeline not yet announced by CBP)

The 80-day window for recently-liquidated entries is actively narrowing. Every week that passes moves some entries further outside Phase 1’s scope. Filing promptly is important.

Key Takeaways

• IEEPA tariff refunds are real government refunds, not estimates or projections — they are required by Supreme Court ruling and CIT order
• Approximately $166 billion is owed to roughly 330,000 U.S. importers
• Phase 1 claims (open since April 20, 2026) cover unliquidated entries and those liquidated within the past 80 days
• Only IEEPA tariff surcharges (9903.01.xx codes) are refundable — Section 301 and Section 232 duties are not
• Refunds include statutory interest from the original duty payment date
• The CAPE portal at ACE is the filing mechanism; CBP targets 60–90 days from submission to ACH disbursement

If you imported goods from China, Canada, Mexico, or other IEEPA-affected countries between February 2025 and February 2026, your business may have a significant refund waiting. Check your eligibility or connect with a recovery specialist to review your actual entry records.