Your IEEPA Refund
Questions Answered

You must apply — refunds are not automatic. CBP is building the CAPE portal (expected ~April 20, 2026) for claim submissions. You must actively submit your claim. For liquidated entries, you must also file protests within 180 days of liquidation — before CAPE even opens. Taking no action means receiving no refund.

The Importer of Record (IOR) is the company listed on CBP Form 7501 (Entry Summary) for each shipment. The IOR is responsible for the duties and is the only party entitled to the refund. If your company's EIN appears as the IOR on affected entries, you qualify. If you purchased imported goods from a domestic distributor or supplier, you are generally not the IOR and cannot file directly.

Covered: IEEPA "fentanyl" tariffs on Canada, Mexico, and China (Feb 4, 2025 onward) and IEEPA "reciprocal" tariffs on all other countries (Apr 2, 2025 onward) — both through Feb 24, 2026. NOT covered: Section 301 China tariffs, Section 232 steel and aluminum duties, anti-dumping duties, and countervailing duties. These remain in force under separate legal authority.

Each country has its own start date and tariff structure. China, Canada, and Mexico are covered from February 4, 2025. Most other countries are covered from April 2, 2025. You can file a single CAPE declaration covering all eligible entries across all countries — you don't need separate filings per country.

If your broker filed as the IOR on your entries, the legal picture is more complex. In most cases, the broker files as agent for the importer and the actual company receiving goods is the beneficial IOR. Review your broker agreements carefully and consult a trade attorney or customs professional to clarify your specific situation before filing.

Under 19 U.S.C. § 1514, when CBP liquidates (finalizes) a customs entry, you have 180 days from that liquidation date to file a formal protest challenging the duties assessed. Miss this deadline and you permanently lose your ability to recover duties on that entry through administrative means. The deadline runs independently for each entry based on its specific liquidation date — not a single universal date.

Log into your ACE Secure Data Portal at ace.cbp.dhs.gov and check the liquidation status of each entry. Your customs broker can also pull this information on your behalf. Any entry showing a liquidation date and status of "liquidated" should trigger an immediate assessment of the protest deadline.

CAPE stands for Consolidated Administration and Processing of Entries — CBP's new ACE-based system for processing IEEPA refund claims. Importers upload a CSV listing all affected entries. CAPE auto-removes IEEPA HTS codes, recalculates duties, and schedules electronic refund payments. As of late March 2026, CAPE was 40–80% complete across its four functional areas. Target launch is approximately April 20, 2026.

CBP no longer issues paper refund checks. All IEEPA refunds will be paid electronically via ACH bank transfer. You must be enrolled in CBP's ACH Refund program through your ACE portal — with your current business bank account and routing number on file — before CBP can issue any payment to you. Without enrollment, your refund will be held even if your claim is fully approved.

Yes. You can choose which entries to include in your CAPE submission. However, entries not included will not be refunded and the opportunity may close permanently if their protest windows expire. It generally makes sense to include all qualifying entries to maximize your total recovery.

The Court of International Trade has ruled that refunds must include statutory interest at 6% per year for corporations, accruing from the date you paid each duty until CBP issues your refund. For example, a $500,000 duty payment made in June 2025 accrues approximately $30,000 per year in interest until paid. The longer CBP takes to process claims, the larger your total recovery.

As the Importer of Record, you are legally entitled to file the refund claim. However, if you raised prices to offset tariff costs, customers may assert legal rights to a share of your refund — particularly if contracts included cost-plus pricing, tariff surcharge line items, or duty drawback sharing clauses. This is a growing area of commercial litigation. Review your supply chain contracts and consult an advisor before filing and assuming you can retain the full refund.

The government has reserved the right to challenge aspects of the refund obligation. An appeal could affect timelines and potentially the scope of recoveries for some importers. Filing formal protests for all liquidated entries is your strongest protection — it keeps your legal claim alive through any government appeal or court challenge, regardless of what happens with CAPE.

Generally, yes. If IEEPA tariffs were previously deducted through cost of goods sold or capitalized into inventory, a refund typically results in taxable income when received. The interest component is also generally taxable as ordinary income. Consult your CPA or tax advisor for guidance specific to your accounting treatment and tax situation. This is an area where professional advice is important.

Yes. The Tariff Advance Program offered by Tariff Recoveries USA allows importers with verified claims of $500,000 or more to sell their refund receivable for an immediate lump-sum cash advance. The advance is structured as a receivable purchase — not a loan — so no debt appears on your balance sheet. Cash is typically wired within 5–10 business days of approval. Visit the Get Help page for details.