IEEPA Refunds Explained:
How to Claim IEEPA Tariff Refunds Before the Window Closes
The CAPE Process, Explained
Inside the largest customs refund operation in US history
CAPE — the Consolidated Administration and Processing of Entries — is the new electronic refund portal that Customs and Border Protection built specifically to handle IEEPA refunds at scale. It lives inside ACE, the same system that licensed importers and customs brokers already use to file entries, declare goods, and communicate with CBP.
The agency designed CAPE around a single principle: process refunds in bulk rather than one entry at a time. That matters because some importers brought in thousands of shipments during the IEEPA period. Filing a separate refund request for each one would have collapsed the system. Instead, importers (or their brokers) upload a single CSV file listing every entry number they want refunded, and CBP processes the entire batch as one declaration.
The Phase 1 window
CBP is rolling out CAPE in phases, and the first phase is narrow. Phase 1 only covers entries that are either still unliquidated by Customs, or that have been liquidated within the past 80 days. "Liquidation" is the formal term for when CBP closes the file on an entry and treats the duties as final. Most entries from the last ten months haven't been liquidated yet — those are eligible. Older entries, particularly those from spring and summer 2025, are racing against the clock.
Once an entry passes the 80-day post-liquidation window, it's no longer eligible for CAPE Phase 1. The only paths forward become later CAPE phases (which don't yet have launch dates) or direct litigation through the US Court of International Trade, a slower, more expensive route.
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IEEPA Refund FAQ
Common questions about the CAPE process
What is the CAPE process?
CAPE — Consolidated Administration and Processing of Entries — is the federal system created by U.S. Customs and Border Protection to process refund requests for duties imposed under IEEPA. Rather than pursuing refunds entry by entry, CAPE allows importers or their licensed customs brokers to submit a single declaration covering thousands of entries. CBP then recalculates the duties and issues a consolidated refund with interest.
Why are IEEPA tariff refunds available?
The Supreme Court ruled 6-3 in February 2026 that IEEPA does not authorize tariffs. The Court of International Trade subsequently ordered the administration to begin reimbursing importers. CBP launched Phase 1 of CAPE on April 20, 2026 to begin processing claims.
How much money is available?
Approximately $166 billion in IEEPA duties were collected from more than 330,000 importers across 53 million shipments between April 2025 and February 2026. CBP has confirmed that roughly 82% of that — about $127 billion including statutory interest — is eligible for refund in Phase 1.
Are refunds automatic?
No. Nothing happens automatically. Every dollar recovered requires an importer to initiate, file, and manage their own claim. If you don’t file, you don’t get paid.
Who is eligible to file?
Only the importer of record or the licensed customs broker who filed the original entries can submit a CAPE Declaration. Refunds are paid to the importer of record — the entity CBP recognizes as responsible for entry compliance and duty payment. Downstream buyers who purchased domestically from a distributor are not eligible to claim directly from CBP.
What entries qualify under Phase 1?
Phase 1 is limited to unliquidated entries and entries liquidated within 80 days of the CAPE submission date. To be eligible, the entry must have had at least one IEEPA-specific HTS Chapter 99 number declared, must exist electronically in ACE, and must not be subject to an exclusion category.
What tariffs are NOT refundable?
Section 232 tariffs on steel, aluminum, autos, copper, lumber, and semiconductors remain in force and are not refundable. The 10% global Section 122 surcharge that replaced IEEPA on February 24, 2026 is legally distinct and also not eligible for a CAPE refund.
Does my refund include interest?
Yes. CBP adds statutory interest running from the date of original duty payment through the date of liquidation or reliquidation. For the quarter beginning January 1, 2026, the applicable rate is 7% for non-corporate filers and 6% for corporations.
How long does it take to receive a refund?
Valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further CBP review.
What happens to entries that don’t qualify for Phase 1?
For entries that do not qualify for Phase 1, it is important to monitor protest deadlines — typically 180 days from liquidation — to preserve your legal right to a refund. Phase 2 is expected to extend to older liquidated entries, but no launch date has been announced. Expect guidance in summer 2026.
What do I need to do before I can file?
Three things need to be in place before filing a CAPE Declaration: an ACE Secure Data Portal account, ACH enrollment for electronic refund receipt (a separate step from ACH payment setup — CBP will validate a claim but hold the refund until bank information is on file), and a compiled list of every entry on which IEEPA duties were paid.
Can my attorney or advisor handle the filing for me?
The short answer: partly. CBP only allows the importer of record or the licensed customs broker who filed the original entries to submit a CAPE Declaration — attorneys cannot file directly. But the work that determines whether you get paid — or lose your claim entirely — happens before anyone presses submit. Auditing entries for eligibility, ensuring no ineligible entries invalidate your declaration, coordinating ACH enrollment, and navigating entries that fall outside Phase 1 all require expertise most internal teams don’t have. Incentify can connect you with specialists who manage that process end-to-end.
What Disqualifies Most Claims
The six most common refund mistakes.
Based on early CAPE filing patterns, these six misconceptions are responsible for the majority of rejected claims and wasted effort. Understanding them up front saves time, money, and frustration.
01
Confusing IEEPA with Section 232 or 301
Steel, aluminum, autos, copper, semiconductors, and Chinese goods under Section 301 were all subject to tariffs imposed under separate authorities. None of those tariffs were affected by the Supreme Court ruling, and none are refundable through CAPE.
02
Not being the Importer of Record
If your supplier shipped DDP and handled customs, they’re the IOR — not you. If you bought from a US distributor, the distributor paid the tariff at the border and may be eligible; you absorbed the price increase but have no direct claim.
03
Waiting too long on older entries
Entries liquidated more than 80 days ago fall outside Phase 1 entirely. They aren’t gone forever — later CAPE phases will likely cover them — but the path becomes slower and more uncertain. Filing what’s eligible now preserves the rest.
04
Filing without clean entry data
A single formatting error in the CAPE CSV file rejects the entire declaration, forcing a full resubmission. Brokers with experienced compliance teams catch these before submission. Direct filers often don’t.
05
Forgetting ACH enrollment
CBP can only refund money to bank accounts already enrolled in their electronic payment system. An importer can have a perfectly valid claim approved and still wait weeks for the money because their banking information isn’t on file.
06
Receiving goods via FedEx or UPS
If your packages came in via express courier with the carrier acting as the broker of record, FedEx and UPS are handling those refunds themselves and passing them back to customers directly. You don’t file separately.
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