See exactly what you're owed in tariff refunds.

On February 20, 2026, the Supreme Court ruled in Learning Resources Inc. v. Trump and Trump v. V.O.S. Selections that IEEPA does not authorize the President to impose tariffs. CBP stopped collecting IEEPA tariffs on February 24, 2026.

Refundable: IEEPA fentanyl tariffs (HTS 9903.01.xx) and IEEPA reciprocal tariffs (HTS 9903.02.xx) collected between April 5, 2025 and February 20, 2026.

NOT refundable: Section 232 (steel, aluminum, autos, copper, semiconductors), Section 301 (China), Section 122 (the current 10% replacement tariff), AD/CVD duties, and standard MFN duties. Only IEEPA was struck down.

Refunds go to the Importer of Record (IOR) — or to whoever the IOR designated on CBP Form 4811 (the "Notify Party") at the time of entry. The refund cannot be redirected after the fact.

If you bought goods DDP (Delivered Duty Paid) from a supplier, the supplier was the IOR and gets the refund. Recovering your share is a private contract matter between you and them, not something CBP handles.

If a courier or freight forwarder (like UPS, FedEx, or DHL) was your IOR, they receive the refund first and then pass it through to you according to their internal process.

CAPE (Consolidated Administration and Processing of Entries) is CBP's new electronic refund system inside the ACE Portal. It went live April 20, 2026 at 8 AM EDT.

To file:

1. Log into the ACE Secure Data Portal (Importer or Broker sub-account)
2. Open the new "CAPE" tab
3. Click "Upload" → download the CSV template
4. Fill in entry numbers (one per row, max 9,999 per declaration)
5. Upload, wait for two rounds of validation, get a CAPE claim number

Important: Only the IOR or the licensed customs broker who originally filed the entry can submit a CAPE Declaration. Once accepted, declarations cannot be amended. Errors require a new declaration.

CAPE Phase 1 accepts two categories of entries:

• Unliquidated entries with at least one IEEPA Chapter 99 code
• Entries liquidated within the last 80 days from your filing date (rolling window)

Phase 1 will accept but not immediately refund entries with status of "Suspended," "Extended," or "Under Review" (including AD/CVD entries). These wait for Commerce to lift suspension, then get processed.

CBP estimates Phase 1 covers about 63% of all eligible IEEPA entries. The other 37% — fully liquidated entries beyond the 80-day window, drawback entries (Type 47), and reconciliation entries (Type 09) — will be addressed in later CAPE phases. No timeline yet.

CBP pays statutory interest under 19 USC §1505(c) from the date you originally deposited duties through the date CBP liquidates or reliquidates your entry.

For Q2 2026, the rates are 7% for non-corporate IORs and 6% for corporate IORs, compounded daily. Rates can change quarterly with IRS announcements.

Our estimator uses simple annual interest as an approximation. The real CBP calculation compounds daily, so your actual refund will be slightly higher than our estimate. The difference is typically less than 1%.

CBP says refunds will be issued within 60-90 days after a CAPE Declaration is accepted, unless a compliance concern triggers further review. Acceptance itself can take 2-4 weeks after submission.

Realistic timing for a clean filing in May 2026: ACH funds arriving August through October 2026.

All refunds are paid via ACH only — CBP no longer issues paper checks (since February 2026). Your ACE Portal account must have current ACH banking on file before filing, or the refund gets held until you provide it.

Yes — under 19 CFR §159.1, when CBP liquidates or reliquidates an entry, it nets all over- and under-payments on that entry. So if an entry has an IEEPA refund due but also an unpaid Section 232 underpayment, CBP offsets them.

CBP can also divert your refund to cover any other "legally fixed and undisputed" debts you owe to the US government — unpaid duties on other entries, unpaid penalties, or other federal obligations.

If you have any open CBP debt, expect your refund to be smaller than our estimate.

USMCA-eligible goods from Mexico or Canada that used HTS 9903.01.04 (USMCA-MX) or 9903.01.14 (USMCA-CA) paid 0% IEEPA duty at entry. There's nothing to refund on these.

Our tool flags entries with these zero-rate IEEPA tracking codes — they should still be included on your CAPE Declaration to officially remove the IEEPA designation, but they don't generate refund dollars.

Special note: Goods entered for consumption from Canada or Mexico between March 4-6, 2025 are NOT refundable, because the USMCA exception didn't take effect until March 7, 2025.

AD/CVD entries are accepted in CAPE Phase 1, but the refund is deferred. CBP will validate the claim and remove the IEEPA codes, but won't liquidate or refund until the Department of Commerce lifts suspension and issues final liquidation instructions for that AD/CVD case.

This often takes 6-18 months after Commerce issues instructions. File now to lock your place in the queue.

Entries liquidated more than 80 days ago are not eligible for CAPE Phase 1. Don't file a protest reflexively — talk to a licensed customs broker first, because protest strategy depends on the specific entry, the AD/CVD status, and whether Phase 2 may cover your entries before action is needed.

General options to discuss with your broker:

• If liquidated within the last 180 days: A formal protest under 19 USC §1514 may preserve your refund right while waiting for Phase 2
• If liquidated more than 180 days ago: Direct suit in the US Court of International Trade may be required; statute of limitations is generally 2 years

CBP estimates a Phase 2 announcement sometime in summer 2026. No firm date.

CBP published a complete CAPE error code table on April 29, 2026. The most common rejections:

• Wrong filer: You're not the IOR or the broker who filed the entry
• No IEEPA code: Entry has no 9903.01.xx or 9903.02.xx HTS code
• Already submitted: Each entry can only appear on one accepted declaration
• Outside Phase 1 window: Liquidated more than 80 days ago
• Surety-paid: Duty was paid by your surety bond, not directly by you
• ACH not enrolled: Validates the claim but holds the refund
• CSV format errors: Bad headers, extra columns, special characters in entry numbers

Because declarations cannot be amended, a single bad entry can't be fixed in place — you have to remove it and submit a new declaration.

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