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Recovering IEEPA Duties on Canadian Imports: A Country-Specific CAPE Refund Guide

If you imported Canadian-origin goods between February 2025 and February 2026, your entries almost certainly carried a 25% IEEPA tariff line — or 10% if the merchandise was an energy product. This page walks through how Canadian entries map to CAPE Phase 1 eligibility, what to verify on your CBP-7501s, and the country-specific factors that affect your refund.

Quick Facts: EO 14193

  • Executive Order: EO 14193
  • Duty rate: 25% on most goods, 10% on energy products
  • Effective: February 2025 through February 24, 2026
  • HTS Chapter 99: Within the IEEPA umbrella range 9903.01.25 – 9903.01.70
  • Stopped: CSMS #67834313 (February 24, 2026), following the Supreme Court ruling in Learning Resources, Inc. v. Trump

What the IEEPA tariff on Canadian imports actually was

EO 14193 imposed a duty under the International Emergency Economic Powers Act (IEEPA), structured as an additional Chapter 99 line on top of the underlying tariff classification. That structure matters for refunds: even if your Canadian entries qualified for USMCA preference (with a zero rate on the underlying HTS), the IEEPA line was assessed separately. Your refund target is that IEEPA line, not the underlying classification.

Energy products from Canada were assessed at a reduced 10% rate. The CAPE refund mechanism does not differentiate between the two rates — it refunds the IEEPA duty actually paid, line by line.

Are your Canadian entries CAPE Phase 1 eligible?

Phase 1 covers two pools:

  • Unliquidated entries — entries CBP has not yet finalized (acceptance + 45 days defaults to liquidation)
  • Recently liquidated entries — entries liquidated within roughly 80 days before the filing date can be reliquidated on the next business day

The standard Phase 1 exclusions still apply to Canadian entries:

  • Antidumping / countervailing duty (AD/CVD) content
  • Pending protests under 19 U.S.C. § 1514
  • Drawback claims
  • Reconciliation entries
  • Warehouse entries
  • Entries with extended, suspended, or "under review" liquidation status

For each Canadian entry you intend to file under CAPE, verify on the CBP-7501 entry summary that there is at least one IEEPA HTS line in the 9903.01.25 – 9903.01.70 range and that the entry status is not in any of the excluded categories above.

Country-specific factors for Canadian importers

USMCA reconciliation

If you filed your Canadian entries with a USMCA claim, your underlying duty was already zero — but the IEEPA Chapter 99 line was still assessed and paid. CAPE refunds the IEEPA line; the USMCA claim on your underlying classification is unaffected. There is no need to withdraw or modify the USMCA claim to file under CAPE.

Energy products at the 10% rate

Crude petroleum, natural gas, and other qualifying energy products carried a 10% IEEPA rate instead of 25%. Confirm the rate that was actually assessed on each entry summary line before estimating your refund — using the wrong rate inflates the expected payout and triggers reconciliation issues later.

Customs broker authorization

If you used a customs broker to file your Canadian entries, that same broker (or a new one) needs explicit CAPE authorization to file declarations on your behalf. See our customs broker authorization guide for the exact ACE Portal steps.

Your recovery options

  • CAPE Phase 1 — primary path for unliquidated and recently-liquidated Canadian entries
  • Protest under 19 U.S.C. § 1514 — file within 180 days of liquidation as a parallel safeguard, even if you also use CAPE
  • CIT litigation — for fully liquidated Canadian entries outside both windows, a Court of International Trade lawsuit may be the only remaining path

Most Canadian importers benefit from a multi-channel strategy. See our CAPE, protest, or CIT decision guide to map your entries to the right combination.

Next steps

  1. Pull all CBP-7501s for Canadian-origin entries with a date of entry between February 2025 and February 24, 2026.
  2. Confirm at least one Chapter 99 line in the 9903.01.25 – 9903.01.70 range per entry.
  3. Filter out AD/CVD, drawback, pending protest, reconciliation, warehouse, and suspended entries.
  4. Estimate your refund using our IEEPA tariff refund calculator.
  5. Use the 7-step CAPE filing guide to prepare your declaration — or get a free assessment to map your entries to the right path.

Get a free Canadian entries assessment

Canadian importer FAQs

Are Canadian-origin entries eligible for CAPE Phase 1 refunds?

Yes, in most cases. Unliquidated entries with at least one IEEPA Chapter 99 line (within 9903.01.25 – 9903.01.70) and recently-liquidated entries within the Phase 1 reliquidation window are generally eligible. Entries with pending protests, AD/CVD content, drawback claims, reconciliation status, warehouse status, or suspended liquidation are excluded from Phase 1.

My Canadian entry was for energy products at the 10% rate. Does that change anything?

The CAPE refund mechanism is the same — the system refunds the IEEPA duty actually paid, whether at 25% or the energy-product 10% rate. Make sure the IEEPA HTS line and the duty amount on your CBP-7501 entry summary match the rate that was actually assessed, then file under standard CAPE Phase 1 procedures.

I claimed USMCA on my Canadian entries. Why did I still pay IEEPA tariffs?

EO 14193 was structured to apply on top of the USMCA preference: the underlying duty rate could still be zero under USMCA, but the IEEPA "additional duty" was assessed separately as a Chapter 99 line. CAPE Phase 1 refunds the IEEPA layer; the USMCA classification on your underlying line is not affected.

What if my Canadian entries are already past the Phase 1 window?

File a protest within 180 days of liquidation under 19 U.S.C. § 1514, even if you also intend to use CAPE. For entries that are fully liquidated and outside both the Phase 1 reliquidation window and the protest window, a CIT lawsuit may be the only remaining path. See our guide on choosing between CAPE, protest, and CIT.

Disclaimer: CAPE Portal Guide is not a law firm, customs broker, or government agency. Country-specific rules and stacking interactions can be complex; consult a licensed customs attorney or broker for entry-level decisions.