IEEPA Tariff Refunds: Who Can Claim, How CAPE Works, and the Deadlines

The importer of record on an entry that paid an IEEPA tariff between 3 February 2025 and 24 February 2026. That covers the reciprocal tariffs and the fentanyl-related tariffs on China, Canada and Mexico. The refund goes to the importer of record or a party it has designated with CBP, not to the foreign seller or the end customer.

Through CAPE, a tool inside CBP's ACE system. You or your customs broker upload a CSV file of entry summary numbers; CBP removes the IEEPA duty from each eligible entry and pays the difference with interest by ACH. Post-summary corrections cannot be used to start an IEEPA refund.

There is no single closing date, but each entry has its own clock. CAPE accepts an entry until 80 days after it liquidates. From day 81 to day 180 only the protest period remains. After 180 days the liquidation is final, and CAPE Phase 3 takes those entries only from importers who are plaintiffs at the Court of International Trade. Formal entries usually liquidate about 314 days after entry, so entries from late 2025 and early 2026 are the ones on the clock now.

As of October 2026 CBP refunds finally liquidated entries only for plaintiffs. Importers in that position are filing their own cases at the Court of International Trade, where the general limit is two years, or waiting on a pending motion to certify a class and on the government's appeal of the refund orders. This is a decision to make with trade counsel, and soon.

CBP says refunds generally arrive 60 to 90 days after a declaration is accepted, unless it flags the declaration for review. Interest is added automatically. By 11 September 2026 CBP had accepted about $134.7 billion in claims and sent about $122 billion, including interest, to the Treasury for payment.

No. The Supreme Court ruling covers only tariffs imposed under IEEPA. Section 232 duties, China's Section 301 duties, antidumping and countervailing duties stay, and CBP keeps them when it recalculates an entry. The Section 122 surcharge of February to July 2026 is being litigated separately.

Not through this process. The court's refund order expressly leaves the de minimis question to a separate case, so parcels that paid duty only because the $800 exemption was suspended are not covered yet.

IEEPA tariffs are gone, but they were replaced. Since 24 July 2026 goods from 60 economies pay a forced-labor Section 301 tariff of 10% or 12.5%, with exemptions by tariff line, on top of the regular duty and any China Section 301 or Section 232 duty. The rate depends on the product and origin, so check each one.