The refund process has multiple steps, hard deadlines, and government systems that most importers have never used. Here is exactly what needs to happen — in the right order — to protect and maximize your recovery.
This is not a simple government form. Here is what a successful IEEPA refund claim actually requires.
Refunds apply specifically to Chapter 99 IEEPA tariff add-on codes. Identifying every qualifying HTS code across potentially hundreds of entry summaries requires customs classification expertise.
Every liquidated entry has its own 180-day clock. Miss any one window and that entry's refund is gone permanently. Tracking these across a full year of imports is a substantial administrative task.
CBP's ACE system is a government trade platform most importers have never used independently. ACH enrollment, entry status tracking, and protest filing all require ACE experience.
CAPE will require a precisely formatted CSV file with entry-level data. One formatting error can delay or invalidate your entire submission — with 330,000+ importers all filing at the same time.
If you passed tariff costs to customers, legal review of your supply chain agreements is needed before filing — or you may be blindsided by customer claims after receiving your refund.
The government has reserved the right to challenge aspects of the refund order. Strategy decisions about protests, CAPE timing, and court filings depend on monitoring these developments in real time.
Follow these steps in this exact order. Skipping any step or doing them out of order risks your recovery.
Only the company listed as Importer of Record (IOR) on CBP Form 7501 can claim the refund. Pull your entry summaries and confirm your EIN appears as the IOR on each affected entry. Contact your customs broker to verify IOR status for any entries you're unsure about.
Log into ACE at ace.cbp.dhs.gov. Navigate to ACH Refund enrollment. Enter your business bank account and routing number. Complete verification. CBP launched this electronic refund system on February 6, 2026 — and it is a hard requirement. No enrollment = no payment, even if your claim is fully approved.
Check ACE for the liquidation status and date of every entry from the covered period. For any liquidated entry, calculate the 180-day deadline and file a formal protest immediately through ACE — or authorize your customs broker to do so via Power of Attorney. This is your most time-critical action.
Pull all CBP Form 7501 entry summaries for Feb 4, 2025 – Feb 24, 2026. Identify all Chapter 99 IEEPA HTS add-on codes. Compile ACH/PMS duty payment records and broker invoices. Verify country of origin for each affected entry. Check liquidation status for all entries in ACE.
If you raised prices to offset tariff costs during 2025, review your supply chain agreements before filing. Look for cost-plus pricing structures, tariff surcharge line items, duty drawback clauses, or other provisions that might give customers a legal basis to claim a share of your refund. Consult an advisor if you find relevant provisions.
When CBP's CAPE portal opens, log into ACE and navigate to the CAPE Declaration portal. Upload your prepared CSV with complete entry-level data. CAPE will automatically remove IEEPA HTS codes, recalculate duties, and schedule your refund. Submit on day one — do not wait. With 330,000+ importers filing simultaneously, early submission matters.
Once your refund is received, work with your CPA to account for it correctly. IEEPA refunds are generally treated as gain contingencies and recorded when received. Assess tax implications of the refund and associated interest income. Evaluate whether intercompany or customer agreements require sharing any portion of the recovery.
Pull these records now. Having them organized before CAPE opens means faster processing and a stronger claim.
Every step in this process has a deadline, a technical requirement, or a legal nuance. Our trusted partner Tariff Recoveries USA manages every step end-to-end — at zero upfront cost to you.
No cost. No obligation. A specialist will respond within 24 hours.