How to check whether you are owed an IEEPA tariff refund

In February 2026 the Supreme Court held that the tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful. U.S. Customs and Border Protection (CBP) then built a refund channel inside its ACE system. If you imported goods while those tariffs were being collected, you may be owed money, and it will not necessarily arrive without you or your broker asking for it.

This guide is the short version: how to find out whether you paid IEEPA duties, whether your entries qualify, who can file, and what to expect on timing. The numbers behind the refund calculation are in the companion guide on calculating your IEEPA refund entry by entry. This is general information, not legal or customs-brokerage advice. CBP changes its process in phases, so check CBP's IEEPA refund page for the current rules; the description below reflects that page as last updated September 2, 2026.

Step 1: Were you the importer of record?

The refund goes to whoever paid the duty to CBP: the importer of record (IOR) on the entry. That is not always the company that bought the goods.

• If you imported through a customs broker under your own importer number, you are the IOR.
• If a carrier, courier or forwarder was the IOR on your shipments, or you bought on DDP terms and the seller cleared the goods, then that party paid the duty and any claim generally rests with them. Ask them directly whether they are filing and how any refund will be passed on.
• If you paid duties that a marketplace or seller bundled into a price, you have no direct claim with CBP.

Step 2: Find entries that carried IEEPA duty

1. Pull your entry data. Ask your broker for an ACE entry summary export for the period the IEEPA tariffs were being collected (2025 into February 2026), or run the reports yourself if you have an ACE Portal account. Get the entry number, entry date, country of origin, entered value, and the duty by line.
2. Look for the Chapter 99 lines. IEEPA duties were declared with special Chapter 99 tariff numbers on the entry summary (CBP Form 7501). CBP's eligibility test in Phase 1 requires that at least one IEEPA-specific Chapter 99 HTSUS number was declared on the entry. Ask your broker to list which of your entries carry one.
3. Total by entry. Add the IEEPA duty per entry. This is your rough gross exposure before rate checks and interest.
4. Check the entry is in ACE. The entry must exist electronically in ACE and not fall into an excluded category.

Step 3: Understand CAPE and its phases

CAPE stands for Consolidated Administration and Processing of Entries. It is a module in ACE that lets refunds be requested in bulk rather than entry by entry. As CBP describes it:

• Who can file: only the importer of record or the licensed customs broker who filed the entries. Attorneys cannot file on an importer's behalf.
• How to file: a CAPE Declaration, submitted as a CSV file of entry numbers through an ACE Portal account. The filer needs an ACE Portal account and bank account information on file for payment.
• Phase 1: unliquidated entries, and certain entries within a short window after liquidation (CBP describes 80 days).
• Phase 2: entries flagged for reconciliation where the reconciliation entry has not yet been filed, opened June 29, 2026.
• Later phases: CBP has said drawback entries, warehouse entries and other scenarios are addressed in future phases.

Entries that liquidated more than about 90 days ago fall outside CBP's voluntary reliquidation window and are treated separately. Trade-press reports in July 2026 described Court of International Trade orders directing CBP to reliquidate certain finally liquidated entries, with the relief reported as tied to importers who had filed suit and with the government's appeal still pending. Because that is contested and moving, ask your broker or a trade attorney whether it affects your older entries and whether you have a filing deadline to protect.

Step 4: Sort your entries by status

Entry status	What generally applies	Action
Unliquidated	Eligible for CAPE Phase 1 if it carries an IEEPA Chapter 99 number and is in ACE	Include in your CAPE CSV
Recently liquidated (within the CAPE window)	Phase 1 covers certain entries liquidated within 80 days of the CAPE submission	Check liquidation date now; the window closes
Flagged for reconciliation, reconciliation not yet filed	Eligible under Phase 2 since June 29, 2026	Ask your broker to confirm flag status
Liquidated longer ago / final	Outside the voluntary window; litigation route being decided	Ask a trade attorney; check protest and court deadlines

Step 5: What to expect once you file

• Interest. CBP states that refunds include interest, calculated from the date of deposit or payment to the date of liquidation or reliquidation, using the IRS quarterly rate under 19 U.S.C. 1505.
• Timing. CBP says valid refunds are generally issued within 60 to 90 days after acceptance, plus roughly 3 to 5 weeks for ACH processing after liquidation. Treat these as CBP's stated targets, not guarantees.
• No edits after acceptance. CBP states that once a CAPE Declaration is accepted it cannot be amended or cancelled, so check the entry list before submitting.
• Protests and corrections. For entries included in a CAPE Declaration, CBP says post-summary corrections and protests cannot be filed until after liquidation or reliquidation. Do not file a protest and a CAPE claim on the same entry without checking with your broker.
• Refunds go to the ACH account on file. Confirm the bank details in your ACE account are current before you file.

A one-page checklist

1. List every entry from the IEEPA period with entry date, origin, entered value and duty per line.
2. Confirm you were the importer of record; if not, identify who was.
3. Flag entries with IEEPA Chapter 99 numbers.
4. Get liquidation status and date for each flagged entry.
5. Confirm you or your broker has an ACE Portal account with ACH refund details.
6. Decide who files: your broker or you.
7. Submit the CAPE CSV for eligible entries; keep the confirmation.
8. Diary a follow-up 60 to 90 days out, and reconcile refunds received against your schedule.
9. For older or finally liquidated entries, get advice on court or protest options.

Mistakes that delay or shrink a refund

• Assuming the refund is automatic. It runs through a declaration that the IOR or broker files.
• Waiting on entries near a window's edge. The window for recently liquidated entries is short; check dates, not calendar months.
• Submitting without checking the CSV. You cannot amend after acceptance.
• Ignoring a broker's silence. Ask your broker in writing whether they plan to file for you and by when.
• Not reconciling. Compare each refund against your own schedule so you notice partial payments.

Sources

• CBP, "International Emergency Economic Powers Act (IEEPA) Duty Refunds" (cbp.gov, last updated September 2, 2026)
• Trade-press summaries of the Court of International Trade orders of July 2026 (Holland & Knight; Morgan Lewis; Thompson Hine)

Verified September 21, 2026. CBP and the courts are still changing this process. Confirm current phases, deadlines and your own eligibility with your customs broker or a trade attorney.

Frequently asked questions

Who can file an IEEPA refund claim with CBP?

According to CBP, only the importer of record or the licensed customs broker who filed the entries can submit a CAPE Declaration. Attorneys cannot file on an importer's behalf. If a carrier or seller was the importer of record on your shipments, ask them about their filing.

How do I know if my entries paid IEEPA duties?

Check your entry summaries (CBP Form 7501) or an ACE entry summary export for the IEEPA-specific Chapter 99 HTSUS numbers. CBP requires at least one such number on the entry for Phase 1 eligibility. Your customs broker can produce the list.

Do IEEPA refunds include interest?

CBP states that refunds include interest calculated from the date of deposit or payment to the date of liquidation or reliquidation, using the IRS quarterly rates under 19 U.S.C. 1505.

How long does an IEEPA refund take?

CBP says valid refunds are generally issued within 60 to 90 days after a CAPE Declaration is accepted, plus about 3 to 5 weeks for ACH processing after liquidation. These are CBP's stated targets, not guarantees.