IEEPA Tariff Refund 2026: How US Importers Can Claim What They're Owed
Bottom line up front: If your business paid tariffs on imports between February 4, 2025 and February 24, 2026, you may be owed a significant refund — plus 6% statutory interest. CBP's CAPE portal is open now. Phase 1 deadlines are rolling. Act before your entries liquidate past the 80-day window.
What happened: the Supreme Court ruling explained
In February 2026, the US Supreme Court ruled that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded presidential authority. This directly invalidated the so-called "reciprocal tariffs" imposed from April 5, 2025, and the "fentanyl tariffs" on China, Canada, and Mexico imposed from February 4, 2025.
The ruling triggered one of the largest customs refund events in US history. CBP is legally required to return every dollar collected under these unlawful tariff orders — with interest.
| Tariff type | Start date | Countries affected | Rate |
|---|---|---|---|
| IEEPA fentanyl tariffs | Feb 4, 2025 | China, Canada, Mexico | 10–25% |
| IEEPA universal reciprocal | Apr 5, 2025 | All countries (10% baseline) | 10% |
| IEEPA country-specific | Apr 9, 2025 | ~60 countries (China 145%) | 10–145% |
The refund window covers duties paid on any of these tariff lines between February 4, 2025 and February 24, 2026 — the date of the Supreme Court ruling.
How much is owed — and have refunds started?
The numbers are significant:
- $175 billion in total IEEPA duties collected
- 330,000+ US importers affected across 53 million shipments
- $35.46 billion already processed and refunded as of mid-May 2026 (principal + interest)
- Refunds include 6% annual statutory interest from the date of payment
Already hitting bank accounts: Phase 1 refunds are actively being paid. Importers who filed early CAPE Declarations are reporting ACH deposits within 3–5 weeks of their entry liquidating. If you haven't filed yet, every week of delay is a week of interest foregone.
Who is eligible for an IEEPA tariff refund?
Eligibility has two requirements:
- Your imports must fall in the window: Entry date between February 4, 2025 and February 24, 2026
- IEEPA duties must have been assessed: Your Form 7501 entry summaries include Chapter 99 HTS codes (9903.01.xx or 9903.08.xx) with associated duty amounts
Practically speaking, if you imported anything from China in 2025, you almost certainly paid IEEPA tariffs. Vietnam, India, Mexico and other country imports that went through after April 5, 2025 also carry the 10% universal reciprocal tariff that is now refundable.
What's NOT eligible
- Section 301 tariffs on China (pre-existing, separate legal basis — not covered by this ruling)
- Section 232 steel and aluminum tariffs (separate legal basis)
- Standard MFN (Most Favored Nation) base tariff rates
- Imports that entered before February 4, 2025
Phase 1 vs Phase 2: what's the difference?
| Phase 1 (open now) | Phase 2 (pending) | |
|---|---|---|
| Eligible entries | Unliquidated entries + entries liquidated within 80 days of your CAPE filing date | All other liquidated entries from the window |
| Refund timeline | 60–90 days after CAPE acceptance | TBD — expected to take longer |
| Filing mechanism | CAPE tab in ACE portal (live now) | CAPE expansion — no launch date confirmed |
| Urgency | 🔴 High — 80-day window is rolling | Lower — entries are already liquidated |
The 80-day clock: Phase 1 covers entries liquidated within 80 days of when you submit your CAPE Declaration. Entries liquidate on a rolling basis — meaning every day you wait, some entries cross out of Phase 1 eligibility and into Phase 2 (slower, less certain timeline). File Phase 1 as soon as possible.
How to claim your IEEPA refund: step by step
Step 1 — Confirm ACE portal access
Only the Importer of Record (IOR) listed on your Form 7501, or your licensed customs broker, can file a CAPE Declaration. Log into the ACE Secure Data Portal. If you don't have an account, apply at CBP.gov — allow 2–3 business days for provisioning.
Step 2 — Enroll in ACH for electronic refunds
CBP pays refunds via ACH direct deposit only. In your ACE portal account, navigate to your Importer sub-account and add your bank routing and account number. Without this step, your refund cannot be issued.
Step 3 — Pull your eligible entry list
Export your entry history from ACE. You need a list of entry numbers with entry dates in the Feb 4, 2025 – Feb 24, 2026 window on which IEEPA duties were paid. Your customs broker can also pull this from their ABI system if they filed your entries.
Step 4 — Generate your CAPE CSV
CBP requires a specific CSV format — a list of entry numbers, one per row. This is what gets uploaded into the CAPE tab in ACE. Each CAPE Declaration can contain up to 9,999 entry numbers.
Step 5 — Submit in ACE
Log into ACE, navigate to the CAPE tab, and upload your CSV. CBP validates the entries against their records. Accepted entries move to liquidation or reliquidation, which triggers the refund payment.
Step 6 — Wait for your ACH deposit
Valid refunds are typically issued within 60–90 days of CAPE acceptance. Once entries liquidate, ACH deposits arrive within 3–5 weeks. The payment includes your principal refund plus 6% annual interest calculated from your original duty payment date.
Upload your documents — we generate the CAPE CSV for you
Skip the manual work. Upload your ACE export or Form 7501 PDFs. Our tool analyzes eligibility, calculates your estimated refund, and produces a CBP-formatted CAPE CSV ready to submit.
Check my refund eligibility →What if I used a customs broker to file my entries?
Your broker can file the CAPE Declaration on your behalf — they're already authorized as your agent. Send them your entry list (or the CAPE CSV our tool generates) and ask them to submit it. Many brokers are handling IEEPA refunds on a flat-fee or hourly basis. Some are filing on a contingency arrangement (percentage of refund recovered).
If your broker is unfamiliar with the CAPE process, point them to CBP's official CAPE documentation or share the broker handoff PDF our tool generates.
Common mistakes to avoid
- Confusing IEEPA tariffs with Section 301: Section 301 China tariffs (25% on most goods since 2018) are NOT being refunded. Only the additional IEEPA tariffs imposed from Feb 4, 2025 are covered.
- Missing the Phase 1 window: Entries that are actively liquidating will fall out of Phase 1 eligibility 80 days after liquidation. Don't wait.
- No ACH enrollment: CBP cannot issue your refund without bank details in your ACE account. Set this up before you file.
- Filing ineligible entries: Including entries outside the date window or without IEEPA duty codes causes delays and compliance reviews.
The bottom line
The IEEPA tariff refund is real, it's significant, and it's actively being paid out. For most importers who sourced from China, Vietnam, or other countries in 2025, the refund could represent thousands to hundreds of thousands of dollars — depending on your import volume and the tariff rates on your specific HTS classifications.
The mechanics are straightforward once you have your entry list and ACE access. The main risk is waiting too long and losing Phase 1 eligibility for entries that have already liquidated.
Next step: Upload your ACE CSV export or Form 7501 PDFs to our IEEPA Refund Analyzer. Get your estimated refund amount and a CAPE-ready CSV in under 2 minutes — $79 for the full report.
Disclaimer: This article is for informational purposes only and does not constitute legal or customs brokerage advice. Refund eligibility and amounts are subject to CBP review and determination. Consult a licensed customs broker or trade attorney for guidance specific to your import situation.