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Filing CAPE Refund Claims for Mexican-Origin Entries Under EO 14194

EO 14194 imposed a 25% IEEPA additional duty on Mexican-origin imports. Crucially, the structure of the order meant that even USMCA-preferred goods — which carried a zero underlying duty — still paid the 25% IEEPA Chapter 99 line. If you imported from Mexico during the affected window, this page walks through how Mexican entries map to CAPE Phase 1 and what to verify.

What the IEEPA tariff on Mexican imports actually was

EO 14194 imposed a 25% additional duty under IEEPA on Mexican-origin goods, structured as a Chapter 99 line layered on top of the underlying tariff classification. For most Mexican entries, the IEEPA line was the dominant duty cost — the underlying duty was often zero (USMCA-qualifying) or low (most-favored-nation rate). The full 25% IEEPA assessment was concentrated on that single Chapter 99 line.

The Mexican IEEPA program had a more complicated timeline than Canada or China. Multiple pauses, partial pauses, and reinstatements occurred during 2025. From a refund standpoint, this complexity does not change the CAPE process — the system refunds whatever IEEPA duty was actually assessed and paid on each individual entry.

Are your Mexican entries CAPE Phase 1 eligible?

The standard Phase 1 eligibility rules apply to Mexican entries:

• Eligible: Unliquidated entries with at least one IEEPA Chapter 99 line; entries liquidated within roughly 80 days of the filing date
• Excluded: AD/CVD content, drawback claims, pending protests, reconciliation, warehouse status, suspended/extended/under-review liquidation

Pull every Mexican-origin entry from your customs broker or ACE Reports for the affected window and inspect each CBP-7501 individually. Because the policy turned on and off, entries dated within the window may or may not have an IEEPA line — only those that actually paid the line are refund candidates.

Country-specific factors for Mexican-origin importers

USMCA preference is preserved

If you filed Mexican entries with a USMCA claim, your underlying duty was already zero — but the IEEPA Chapter 99 line was still assessed at 25%. CAPE refunds the IEEPA line; your USMCA claim on the underlying line is not affected and does not need to be modified or withdrawn.

Multiple pause periods mean entry-by-entry verification

Unlike Canada (where the policy ran continuously from February 2025) or China (continuous from February 2025), the Mexican IEEPA program had pause windows. You cannot assume that every Mexican entry between February 2025 and February 2026 paid IEEPA duties. Each entry summary must be inspected for the actual presence of an IEEPA Chapter 99 line.

Maquiladora and IMMEX program entries

Goods imported under Mexican maquiladora / IMMEX arrangements still moved across the border under standard CBP entry processes once they entered the U.S. — meaning the IEEPA duty applied based on the U.S. entry, not the Mexican production arrangement. Your refund target is the U.S. entry summary, not the Mexican export documentation.

Your recovery options

• CAPE Phase 1 — primary path for unliquidated and recently-liquidated Mexican entries without AD/CVD content
• Protest under 19 U.S.C. § 1514 — file within 180 days of liquidation as a parallel safeguard
• CIT litigation — for fully liquidated entries outside Phase 1 windows or AD/CVD-excluded entries, a Court of International Trade lawsuit may be the only option

Next steps

1. Pull all CBP-7501s for Mexican-origin entries with dates of entry between February 2025 and February 24, 2026.
2. Inspect each entry summary individually for an IEEPA Chapter 99 line within 9903.01.25 – 9903.01.70 (do not assume — pause windows mean some entries did not carry IEEPA duty).
3. Filter out AD/CVD, drawback, pending protest, reconciliation, warehouse, and suspended entries.
4. Sum the actual IEEPA duty paid (25% of the value reported on the IEEPA line, not 25% of the merchandise total) for refund estimation.
5. Use the 7-step CAPE filing guide or get a free assessment.

Get a free Mexican entries assessment

Mexican importer FAQs

Disclaimer: CAPE Portal Guide is not a law firm, customs broker, or government agency. The Mexican IEEPA timeline included multiple pauses and reinstatements; consult a licensed customs attorney or broker for entry-level decisions.