Why there is a refund to calculate at all
In February 2026 the Supreme Court struck down the tariffs that had been imposed under the International Emergency Economic Powers Act (IEEPA). U.S. Customs and Border Protection (CBP) is now processing refunds to importers who paid those IEEPA duties on entries filed while the tariffs were in effect.
That is good news, but it does not arrive as a check with a number already on it. CBP is refunding based on entry data, and it is on the importer of record (or a broker acting for them) to know which entries were charged the IEEPA duty, at what rate, and how much of that is refundable. This guide walks through building that calculation yourself, entry by entry.
This is general information, not legal, tax or customs-brokerage advice. Confirm your own case against your CBP entry data and, where it matters, a licensed customs broker or trade attorney. Always verify current rates and deadlines on CBP's own site before filing anything.
What you need before you start
Pull together the following for the period you paid IEEPA duty:
- Entry summaries (CBP Form 7501) or your ACE (Automated Commercial Environment) entry summary export
- Entry date for each shipment
- Country of origin for each line
- Entered value (the customs value used to calculate duty)
- The IEEPA duty amount actually charged, as shown on the entry
- Whether a CAPE (CBP's refund-adjustment process for these tariffs) declaration has already been filed or accepted for any of these entries
If you use a customs broker, they can usually pull an ACE entry summary export covering the period for you. That export is the fastest starting point because it already has entry date, origin and value in structured columns.
Calculating your refund, entry by entry
- List every entry from the period the IEEPA tariffs were in force. Put each entry on its own row: entry number, date, origin country, entered value, and the IEEPA duty amount actually charged.
- Attach the rate that should have applied to each entry. IEEPA tariff rates changed several times during 2025 and varied by origin country. Some periods, including a stretch of several weeks in spring 2025 affecting China-origin entries, carried a notably higher rate than the rest of the year. Because the rate schedule changed by country and by date, look up the rate that was actually in force for each entry's specific date and origin rather than assuming one flat rate for the whole period.
- Calculate what should have been charged (entered value multiplied by the correct rate for that date and origin) and compare it to what was actually charged on the entry.
- The difference is your estimated refundable amount for that entry, before CBP's own review.
- Flag entries that have already liquidated. Once an entry liquidates, you generally have a limited window to file a formal protest under 19 U.S.C. 1514 if you disagree with the duty charged (commonly discussed as a 180-day window, but confirm the exact rule and your entry's liquidation date with your broker or CBP, since liquidation timing and protest deadlines are entry-specific).
- Total by month and by origin country. This makes it easier to see where most of your refund is concentrated and which entries to prioritize first.
Comparing your options
| Approach | What it costs | What you get |
|---|---|---|
| Do it yourself in a spreadsheet | Your time | Full control, but you rebuild the rate schedule by hand for every entry date and origin |
| Contingency-fee recovery firm | Typically 15–25% of whatever is recovered | They do the work, but you give up a meaningful share of the refund |
| IEEPA Refund Reconstruction | $299 flat | Entry-by-entry schedule with the rate schedule already modeled, delivered within 24 hours (often within the hour for a clean CSV) |
Where the CAPE process fits in
CBP has been processing these IEEPA refunds through what is generally referred to as the CAPE (Post-Summary Correction / adjustment) declaration route. If you have not filed one, your broker can generally do this once you know which entries qualify. If a CAPE declaration you already filed was rejected, that usually means it needs to be corrected and resubmitted rather than filed fresh, so keep your original submission and the rejection reason on hand.
Because CBP's own process and timeline can change, verify current CAPE filing steps and any published deadlines directly on cbp.gov before you or your broker files anything.
Common mistakes that shrink or delay a refund
- Using one flat rate for the whole period. The rate schedule moved by date and by origin country; applying today's rate (or an average) to every entry misstates the refund.
- Missing the protest deadline on liquidated entries. Once the protest window closes on a liquidated entry, the refund path narrows considerably. Check liquidation dates entry by entry, not by assuming they all liquidated on the same schedule.
- Working from summary totals instead of entry-level data. A single blended number for a quarter cannot show which specific entries are refundable or which are approaching a deadline.
- Not accounting for a rejected CAPE declaration. A rejected declaration does not mean no refund is owed, it usually means the filing needs correction.
- Treating broker statements as a complete substitute for entry data. A monthly broker statement can be a useful cross-check, but it usually summarizes charges rather than breaking out the IEEPA duty component entry by entry, which is what you need to spot the specific refundable lines.
Keeping your own record as refunds come in
As CBP works through the queue, refunds are not necessarily paid out in the order entries were filed. Keep your own entry-by-entry schedule as a running record so you can check incoming refund amounts against what you expected, rather than trying to reconstruct the math after the fact when a payment lands. If a refund amount does not match your schedule, that mismatch is worth raising with your broker before you assume either number is correct.
Want this done for you? The IEEPA Refund Reconstruction report builds this entry-by-entry schedule for you, with the full 2025-26 rate-by-date-by-country schedule already modeled. — see what's included and order →