IEEPA Tariff Refund: The Complete Guide to Getting Your Money Back (2026)

If you paid extra duties under the International Emergency Economic Powers Act (IEEPA) tariffs between February 2025 and February 2026, you are almost certainly entitled to a refund. The Supreme Court struck down these tariffs, and CBP is now processing refunds through a new system called CAPE.

This guide covers everything: who qualifies, how to file, what to do if CAPE doesn’t cover your entries, and how long the whole process takes.

Background: Why You’re Getting a Refund

Between February 1, 2025 and February 24, 2026, the U.S. government imposed emergency tariffs on imports from Canada, Mexico, China, and countries importing Venezuelan oil under the International Emergency Economic Powers Act.

The tariff rates were:

Country	Rate	Executive Order
Canada	25% (10% on energy products)	EO 14193
Mexico	25%	EO 14194
China	20% additional (on top of Section 301)	EO 14195
Venezuelan oil importers	25%	March 2025 EO

On February 20, 2026, the Supreme Court ruled 6–3 in Learning Resources, Inc. v. Trump that IEEPA does not authorize the president to impose tariffs. All IEEPA tariff actions were terminated by executive order the same day, and duties stopped being collected on February 24, 2026.

If you paid these duties, the government owes you that money back.

How Much Can You Get Back?

Your refund equals the IEEPA-specific duties you paid — the amounts collected under HTS subheadings 9903.01.25 through 9903.01.70 (Chapter 99 IEEPA line items).

This does not include:

• Regular MFN duties (those stay)
• Section 301 duties on Chinese goods (separate program)
• AD/CVD duties (separate program)
• Merchandise Processing Fee (MPF) or Harbor Maintenance Fee (HMF)

Example: If you imported $1 million in Canadian manufactured goods and paid 25% IEEPA duty ($250,000) plus 3% regular duty ($30,000), your refund would be approximately $250,000.

Use our IEEPA Refund Calculator to estimate your specific refund amount.

Three Ways to Get Your Refund

There is no single path to recovering IEEPA duties. Depending on your situation, you may use one or more of these methods:

1. CAPE (Consolidated Administration and Processing of Entries)

CAPE is CBP’s primary refund mechanism — a new module built inside the ACE Portal specifically for processing IEEPA duty refunds at scale.

How it works:

• The importer of record (or the broker who filed the entry) uploads a CSV file listing entry numbers
• CBP validates the entries, removes the IEEPA line items, and recalculates duties
• Refunds are issued as a lump-sum ACH direct deposit

CAPE Phase 1 launched on April 20, 2026 and covers:

• Unliquidated entries — set to liquidate 45 days after acceptance
• Recently liquidated entries — within approximately 80 days of filing, reliquidated the next business day

For full Phase 1 rules, read our CAPE Phase 1 deep dive.

What CAPE Phase 1 does NOT cover:

• AD/CVD entries
• Drawback entries
• Entries with pending protests
• Reconciliation entries
• Warehouse entries
• Entries liquidated more than ~80 days ago
• Entries with extended/suspended liquidation

If your entries fall into any of these categories, you need an alternative strategy. Check your eligibility to see which path applies to you.

2. Protests (19 USC § 1514)

A protest is a formal legal challenge filed through ACE within 180 days of liquidation. This is an established CBP process — unlike CAPE, it has decades of legal precedent.

Why file protests even if you’re using CAPE:

• CAPE is brand new and may have technical issues
• Protests protect your rights if CAPE rejects your entries
• The 180-day protest window is a hard deadline — miss it and the option is gone forever
• Protests are required before you can escalate to court

Read our step-by-step protest filing guide for the complete process.

3. CIT Litigation (Court of International Trade)

For entries that are finally liquidated with no pending protest and past the 180-day protest window, a lawsuit at the Court of International Trade may be the only remaining option.

This requires a trade attorney and is more expensive, but it can recover duties that no other method can reach.

When to consider CIT:

• Entries liquidated before mid-2025 (protest window already closed)
• CAPE rejected your entries and protest deadline has passed
• Large dollar amounts that justify legal costs

Step-by-Step: How to File for Your Refund

Step 1: Verify Your Eligibility

Before filing anything, confirm your entries qualify:

• Were IEEPA Chapter 99 duties actually assessed? (Check your entry summaries for HTS 9903.01.xx lines)
• What is the liquidation status? (Unliquidated, recently liquidated, or final?)
• Are there any complicating factors? (AD/CVD, drawback, protests, reconciliation)

Use our eligibility checker to quickly determine your status, or review the detailed criteria.

Step 2: Set Up Your ACE Portal Access

You need an active ACE Portal account with proper permissions. The filer must be either:

• The importer of record, or
• The customs broker who filed the original entry summaries

If you’re working with a broker, they need a valid Power of Attorney. See our ACE setup guide and broker authorization guide.

Step 3: Register ACH Refund Information

All IEEPA refunds are issued via ACH direct deposit only — no paper checks. You need a separate refund account registered in ACE, linked to the importer of record (or a designated refund payee).

This must be done before filing your CAPE declaration.

Step 4: Prepare Your Entry List

CAPE requires a CSV file containing your entry numbers in 11-digit format. Before uploading:

• Screen for exclusion categories (AD/CVD, drawback, etc.)
• Verify liquidation status for each entry
• Remove any duplicates
• Ensure the filer matches the original entry summary filer

See our CSV preparation guide for formatting rules and validation tips.

Step 5: Submit Your CAPE Declaration

Upload your CSV through the ACE Portal CAPE module. Key rules:

• Maximum 9,999 entries per declaration
• Submit multiple declarations if you have more
• You cannot modify a declaration after submission
• Duplicate entries (within or across declarations) will be rejected

Step 6: File Protests as Backup

For each liquidated entry, file a protest within the 180-day window. This runs in parallel with CAPE and protects you if CAPE fails or rejects entries.

Read the protest filing guide for step-by-step instructions.

Step 7: Monitor and Follow Up

After filing:

• CAPE entries are validated by CBP over approximately 45 days
• Refunds are processed after validation — expect 60 to 90 days total from acceptance
• Refunds are consolidated by importer of record and liquidation date into a single lump-sum payment
• Track protest status through ACE

Refund Timeline

Event	Timeframe
CAPE Phase 1 launch	April 20, 2026
CBP validates CAPE declarations	~45 days from acceptance
Refund processing and ACH deposit	60–90 days from acceptance
Protest decision by CBP	Up to 2 years (but often faster)
Future CAPE phases	TBD — expected to cover more entry types

For a complete timeline including all critical deadlines, see our IEEPA tariff refund timeline.

Common Questions

Do I need a lawyer? Not necessarily for CAPE or protest filing, but if your entries are complex (AD/CVD overlap, large dollar amounts, or you need CIT litigation), consulting a trade attorney is strongly recommended.

Can I file CAPE and a protest for the same entry? Yes, but coordinate carefully. If a protest is already pending, CAPE Phase 1 will reject the entry. File the CAPE declaration first, then plan your protest strategy. See our multi-channel strategy guide.

What if I used a customs broker for the original entries? The broker who filed the entry summaries can file the CAPE declaration on your behalf with a valid Power of Attorney. Read our broker authorization guide.

Will I earn interest on my refund? CBP has not confirmed whether interest will be included in IEEPA refunds. This may depend on the refund mechanism (CAPE vs. protest vs. CIT).

What about Section 301 tariffs on China? Section 301 tariffs are a separate program and are not affected by the IEEPA ruling. Only the additional 20% IEEPA surcharge on Chinese goods is refundable.

What You Should Do Right Now

1. Check your eligibility — Determine which refund paths apply to your entries
2. Calculate your estimated refund — Know the dollar amount at stake
3. Read the 7-step guide — Understand the full CAPE filing process
4. Request a free assessment — Connect with vetted trade law professionals who can help maximize your recovery

Time matters. Protest deadlines are running. CAPE Phase 1 is live. The sooner you act, the sooner you get your money back.

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Disclaimer: This guide is for educational purposes only. CAPE Portal Guide is not a law firm, customs broker, or government agency. We connect importers with vetted trade law professionals. For legal advice specific to your situation, consult a qualified trade attorney.

Sources: CBP CSMS #67834313, CBP CSMS #67823350, Supreme Court ruling in Learning Resources, Inc. v. Trump (February 20, 2026), Federal Register 2026-03832.