Check Your IEEPA Tariff Refund
The Supreme Court struck down IEEPA tariffs. CBP is refunding $166 billion to importers. Upload your broker's entry data and see exactly how much you're owed.
- Step 1: Upload your broker's entry summary CSV
- Step 2: Validate every entry against CAPE filing rules
- Step 3: Download a clean, CBP-ready file
No file handy? Try a sample CSV
By the numbers
Background
What Are IEEPA Tariffs?
Starting February 1, 2025, the administration used the International Emergency Economic Powers Act (IEEPA) to impose tariffs on imports through a series of Executive Orders: EO 14193 (Canada), EO 14194 (Mexico), EO 14195 (China), EO 14245 (Venezuelan oil importers, 25%), EO 14257 (reciprocal tariffs, global), EO 14323 (Brazil, 40%), and EO 14329 (India, tied to Russian oil). These tariffs added additional ad valorem duties via Chapter 99 HTS lines.
On February 20, 2026, the Supreme Court held 6-3 in Learning Resources, Inc. v. United States that IEEPA does not authorize the President to impose tariffs. Every IEEPA tariff was invalidated.
The Court Orders Driving Refunds
- March 4-5, 2026: CIT ordered CBP to liquidate and reliquidate entries without IEEPA duties.
- March 20, 2026: Scope expanded to cover all IEEPA duties, including Brazil and India.
- March 27, 2026: Added language directing reliquidation even where liquidation is final.
All orders are suspended as to immediate compliance while CBP builds the refund mechanism.
How it works
How CBP's CAPE Refund System Works
CBP is building CAPE inside ACE with four components: Claim Portal, Mass Processing, Review/Liquidation/Reliquidation, and Refund. The existing approach would require 53.17 million entry-level amendments consuming 4.43 million personnel hours.
The CAPE End-to-End Workflow
- Confirm ACE Portal access and verify you are the importer of record or authorized broker.
- Complete ACH Refund enrollment (mandatory since February 6, 2026).
- Submit a CAPE Declaration with a CSV listing your entry summaries. This tool validates and fixes your CSV so it passes CBP's checks.
- File validations check formatting, submitter authorization, and file integrity. Failure rejects the entire Declaration.
- Entry validations confirm each entry exists in ACE with IEEPA Chapter 99 HTS. Failed entries are dropped, others continue.
- Mass Processing removes IEEPA HTS lines and recalculates duties.
- Review and liquidation/reliquidation scheduled Monday-Thursday with CBP review.
- Refund consolidation groups by liquidation date and issues ACH payment.
Eligibility
Phase 1 Eligibility
Phase 1 covers approximately 63% of affected entries:
- Unliquidated entries with IEEPA duties
- Liquidated within 80 days of your CAPE filing
Phase 1 Exclusions
- Reconciliation-flagged entries and entry type 09 summaries
- Entries designated on a drawback claim
- Entries covered by an open protest
- Entries not filed in ACE or without ACE liquidation status
- Certain AD/CVD entries pending Commerce instructions
- Finally liquidated entries (deferred to later phases)
For importers
What D2C Brands and Importers Need to Know
If you import from China, Mexico, Canada, Brazil, India, or any IEEPA reciprocal tariff country, you are likely owed money. Typical D2C brands importing $5-15M annually may be owed $500K to $3M+ in refunds plus interest.
Consumer pass-through risk: Class actions have been filed alleging companies that passed tariff costs to consumers should share refunds. Consult legal counsel before filing.
Deadlines
Key Deadlines and Timing
- CAPE portal launch: Late April 2026
- Processing time: Up to 45 days from acceptance to liquidation
- Voluntary reliquidation window: 90 days from liquidation (80-day cutoff)
- Refund payment: Within 30 days of liquidation (19 U.S.C. 1505)
- Protest deadline: 180 days from liquidation (19 U.S.C. 1514)
Interest and ACH Enrollment
Refunds include interest from deposit date to liquidation date (19 CFR 24.36). But interest stops accruing if CBP certifies payment and you haven't completed ACH enrollment. As of March 26, 2026, 26,664 importers (78% of IEEPA duty payers, $120B principal) had completed enrollment.
Checklist
Importer Checklist: Get Your IEEPA Refund
- Confirm you are the importer of record and can access ACE Portal.
- Complete ACH Refund enrollment for each importer number.
- If using a third-party payee, update CBP Form 4811.
- Build an entry list of all entries with IEEPA Chapter 99 HTS numbers.
- Tag each entry by liquidation status.
- Use this tool to validate and clean your CSV.
- Submit CAPE Declarations, resolve errors, resubmit as needed.
- Track acceptance dates and refund consolidation timing.
What Can Go Wrong
- File validation rejection: Wrong format, missing data, corrupted CSV. Entire Declaration rejected.
- Entry validation rejection: Entry not in ACE or missing IEEPA HTS. Entry dropped, others continue.
- No ACH enrollment: Refunds rejected until setup is complete.
- Finally liquidated entries: Phase 1 won't process them.
- Interest loss: CBP certifies but can't deliver due to missing ACH data.
- Consumer class actions: Companies that passed tariffs to consumers face lawsuits.
FAQ
Frequently Asked Questions
Did the Supreme Court invalidate all IEEPA tariffs?
Yes. On February 20, 2026, the Supreme Court held 6-3 that IEEPA does not authorize tariffs, invalidating all IEEPA Executive Orders: EO 14193 (Canada), EO 14194 (Mexico), EO 14195 (China), EO 14245 (Venezuelan oil), EO 14257 (reciprocal), EO 14323 (Brazil), and EO 14329 (India).
Does this refund Section 232 or Section 301 tariffs?
No. Only IEEPA-based tariff codes were invalidated. Section 232 and Section 301 tariffs remain in effect under separate statutory authority.
Are refunds automatic?
No. CBP requires CAPE Declarations with CSV uploads, file validations, entry validations, and ACH electronic payment setup.
Who can file for refunds?
The importer of record or the authorized broker who filed the entry summaries. Filing happens in the ACE Portal via the CAPE Claim Portal tab.
What entries qualify for Phase 1?
Unliquidated entries and entries within the 90-day voluntary reliquidation period (80-day operational cutoff). Phase 1 covers about 63% of affected entries.
What entries are excluded from Phase 1?
Reconciliation-flagged entries, drawback-designated entries, entries with open protests, entries not in ACE, certain AD/CVD entries, and finally liquidated entries.
Do I need ACH enrollment?
Yes. Electronic refunds are mandatory since February 6, 2026. Refunds are rejected without completed setup. 78% of IEEPA duty payers ($120B) had completed enrollment as of March 26.
Can I lose interest on my refund?
Yes. No interest accrues when CBP certifies payment within 30 days but can't deliver because you haven't completed ACH enrollment.
How long until I get my refund?
Up to 45 days from CAPE Declaration acceptance to liquidation, then 30 days to payment. Total: approximately 6-8 weeks.
Is my data safe with this tool?
Yes. Your CSV is processed entirely in your browser. No customs data is uploaded to our servers.
Are there consumer class action risks?
Yes. Class actions seek refund sharing from companies that passed IEEPA costs to consumers. Consult legal counsel.
Reference
IEEPA Tariff Glossary
- ACE
- Automated Commercial Environment, CBP's system of record. CAPE is built inside ACE.
- CAPE
- Consolidated Administration and Processing of Entries. Four components: Claim Portal, Mass Processing, Review/Liquidation, Refund.
- CAPE Declaration
- The submission requesting IEEPA refunds, including a CSV listing entry summaries.
- Chapter 99 HTS
- Harmonized Tariff Schedule provisions used to implement IEEPA duties.
- Liquidation
- CBP's final computation and decision on duties owed on an entry.
- Reliquidation
- A change to a prior liquidation, including voluntary reliquidation within 90 days.
- Protest
- Administrative challenge under 19 U.S.C. 1514, filed within 180 days after liquidation.
- Drawback
- Refund of duties upon exportation. Phase 1 excludes drawback-designated entries.