IEEPA Tariff Refunds in 2026: How U.S. Importers Can Actually Get Their Money Back

What Happened and Why It Matters to Your Bottom Line

On February 20, 2026, the U.S. Supreme Court ruled in Learning Resources, Inc. v. Trump that the President exceeded his authority by using the International Emergency Economic Powers Act (IEEPA) to impose tariffs. The ruling invalidated the reciprocal tariff regime that had applied duties of 10% or higher on imports worldwide, including the aggressive escalations targeting China, Canada, and Mexico.

The financial scale is staggering. Between January 2025 and early 2026, IEEPA-based tariffs generated roughly $142 billion in customs revenue. Much of that money was collected from U.S. importers who are now legally entitled to get it back.

But here's what every importer needs to understand: refunds are not automatic. You have to file for them. And the process has strict eligibility windows, technical requirements, and deadlines that are easy to miss.

The CAPE System: How CBP Is Processing Refunds

U.S. Customs and Border Protection is building a new module inside the Automated Commercial Environment (ACE) called the Consolidated Administration and Processing of Entries (CAPE). This is the only mechanism through which IEEPA refund claims will be processed.

CAPE is expected to go live around April 20, 2026, with Phase 1 covering approximately 63% of all entries on which IEEPA duties were paid or deposited.

The process works in four steps:

Step 1: Claim Submission. Importers of record (or their licensed customs brokers) submit a CAPE Declaration through the ACE web portal. This requires uploading CSV files listing the affected entry summaries. The system runs automated checks to verify formatting, completeness, and eligibility.

Step 2: Mass Processing. CAPE automatically removes the IEEPA-related Harmonized Tariff Schedule (HTSUS) codes from each validated entry and recalculates the total duties owed as if the IEEPA tariffs had never been applied.

Step 3. Liquidation or Reliquidation. CAPE schedules a date to finalize each entry. The system processes both liquidation (for entries that haven't yet been finalized) and reliquidation (for entries that were previously finalized but are eligible for correction).

Step 4. Refund Issuance. Refunds are consolidated by importer of record and liquidation date, then paid electronically via ACH. Interest is applied at the current corporate rate of 6%.

CBP estimates it will take up to 45 days from the date a claim is accepted to deliver the refund, assuming no compliance concerns trigger additional review.

What's Eligible in Phase 1. and What Isn't

Phase 1 of CAPE will accept claims for:

Unliquidated entries (entries that CBP has not yet finalized)

Entries within the 90-day voluntary reliquidation window under 19 U.S.C. § 1501

Entries with a status of "Suspended," "Extended," or "Under Review" in ACE, including antidumping and countervailing duty (AD/CVD) entries that remain under suspension

Warehouse and warehouse withdrawal entries (IEEPA codes will be removed, but refunds won't issue until the entry liquidates in the normal warehouse process)

Phase 1 will not cover:

Finally liquidated entries beyond the 90-day reliquidation window (these require a subsequent CAPE phase, with no timeline announced)

Entries flagged for reconciliation or designated on drawback claims

Entries with complex interest calculations involving multiple collection dates on a single entry summary

The Court of International Trade has ordered CBP to eventually process refunds for finally liquidated entries as well, but no firm date has been set for that expansion.

Five Things Every Importer Should Do Right Now

1. Audit Your IEEPA Duty Exposure

Pull every entry summary from 2025 and 2026 that included an IEEPA-related HTSUS provision. Quantify the total duties paid. Separate entries by liquidation status. unliquidated, liquidated within 90 days, and finally liquidated. so you know what's Phase 1-eligible and what isn't.

2. Enroll for Electronic Refunds

CBP announced that all refunds will be issued electronically via ACH starting February 6, 2026. As of the latest reports, nearly 27,000 importers have registered for digital returns, representing about 78% of IEEPA-affected entries. If you haven't enrolled yet, verify your banking details, your ACE account access, and your CBP Form 4811 designations immediately.

3. File Protests on Liquidated Entries

For any entry that has already been liquidated, file a formal protest with CBP within 180 days of liquidation. even if CAPE isn't live yet. This tolls the final liquidation date and preserves your right to a refund. Until there is complete certainty on how the court's order for finally liquidated entries will be implemented, filing protests remains the safest defensive measure.

4. Prepare Your CSV Submissions

CAPE requires entry-level data submitted via CSV upload. Start organizing your entry summaries now. Verify that HTS classifications, duty calculations, and importer of record information are accurate and consistent with what's in ACE. A single data mismatch can delay or reject your claim.

5. Assess Your Financial Exposure

IEEPA duties may have been capitalized into inventory or recorded through cost of goods sold in prior periods. Work with your finance team to evaluate how refunds and any related interest should be reflected in current financial statements. If your commercial agreements include duty-sharing provisions with suppliers or customers, determine who is entitled to the recovered funds.

The Timeline Importers Need to Track

What This Means for Your Landed Cost Strategy

The IEEPA refund isn't just a one-time windfall. It's a signal that the tariff landscape is fundamentally unstable. The duties that drove up your landed costs for over a year were built on legal authority the Supreme Court rejected. Meanwhile, Section 232, Section 301, and the new Section 122 surcharge remain fully in effect.

The importers who come out ahead aren't just the ones who file for refunds fastest. They're the ones who use this moment to rebuild their duty management from the ground up. classifying entries correctly, modeling total landed cost across every applicable duty program, and making sure no dollar leaves their business that doesn't have to.

If your current process depends on spreadsheets, memory, or hoping your broker catches everything, the IEEPA episode just showed you what that approach costs.

This guide reflects information available as of April 3, 2026. The IEEPA refund process is evolving rapidly. Importers should monitor CBP announcements, court filings, and consult with a licensed customs broker to protect their refund rights.