IEEPA Tariff Refunds in 2026: What Importers Need to Know, What to Do Right Now, and How to Check Your Eligibility
If your company imported goods into the United States between February 4, 2025, and February 24, 2026, you may be eligible for a refund of IEEPA tariffs you paid during that period. Whether you qualify, how much you may be owed, and whether you can actually receive a refund depends on several factors specific to your entries, your customs account setup, and the status of each shipment.
At Southern Star Navigation, we have been tracking this situation closely since the beginning. We built a free set of tools and resources to help importers understand where they stand and what steps to take. This article explains what happened, how the refund process is being set up, what you need to have in place, and where things stand as of March 31, 2026.
What Are IEEPA Tariffs and Why Are Refunds Being Discussed
IEEPA stands for the International Emergency Economic Powers Act. Beginning in early 2025, the Trump administration used IEEPA to impose tariffs on imports from a wide range of countries. These included tariffs on goods from Canada, Mexico, and China related to fentanyl trafficking concerns, as well as broader reciprocal tariffs announced on April 2, 2025 that applied varying rates across most trading partners.
On February 20, 2026, the United States Supreme Court ruled 6 to 3 in Learning Resources, Inc. v. Trump that IEEPA does not authorize the President to impose tariffs. That authority belongs to Congress under Article I of the Constitution. Following that ruling, the Court of International Trade directed CBP to begin processing refunds of duties collected under IEEPA.
IEEPA tariffs stopped being collected on February 24, 2026. A replacement 10% tariff under Section 122 of the Trade Act of 1974 took effect the same day and is currently set to run through July 24, 2026. Section 232 tariffs on steel, aluminum, and autos and Section 301 tariffs on Chinese goods were not affected by the ruling and remain in force.
It is important to understand that the refund process has not started yet. CBP is building the system that will handle refunds and it is not yet open. The information below explains what is being built, who may be eligible, and what you can do to prepare.
Who May Be Eligible for a Refund
Eligibility for an IEEPA tariff refund is not automatic and it is not universal. There are several conditions that need to be met.
To be potentially eligible, your company generally needs to have been the importer of record on entries that were subject to IEEPA-specific tariff codes, meaning HTS codes beginning with 9903 under Chapter 99. Not every import during the IEEPA period carried these codes. Entries that only carried Section 232 or Section 301 duties are not eligible under this refund process.
Your entries also need to be in an eligible status. CBP’s new refund system called CAPE, which stands for Consolidated Administration and Processing of Entries, will handle refunds for unliquidated entries in standard status during Phase 1. As of March 31, 2026, CBP expanded the scope of Phase 1 significantly. Entries with Suspended, Extended, or Under Review status will now be accepted on a CAPE Declaration, as will warehouse, warehouse withdrawal, and AD/CVD entries. However, for these entry types CAPE will only remove the IEEPA HTS codes — the actual refund will not be processed immediately but will follow when those entries liquidate in the normal course. The following entry types remain excluded from Phase 1 entirely: entries flagged for reconciliation, entries designated on a drawback claim, entries covered by an open protest, entries not filed in ACE or without a liquidation status in ACE, and AD/CVD entries where the Department of Commerce has already issued liquidation instructions.
If your entries have already liquidated, meaning CBP has made a final duty determination, your situation is different depending on whether that liquidation is final or not final. Entries where liquidation is not yet final may still be reliquidated without regard to IEEPA duties under the current court order. On March 27, 2026, the Court of International Trade ordered CBP to reliquidate all IEEPA entries including finally liquidated ones. However, on March 31, 2026, CBP filed a declaration confirming that Phase 1 of CAPE will not include finally liquidated entries due to the complexity of processing them within the Phase 1 timeline. CBP stated that the capability to process finally liquidated entries will be developed in a subsequent phase of CAPE. The court order still stands and CBP is obligated to address these entries, but the timing is uncertain. Importers with finally liquidated entries should consult a licensed trade attorney about their specific situation.
The amount of any potential refund depends entirely on what IEEPA duties your company actually paid on eligible entries. Interest may also be applicable under 19 U.S.C. Section 1505 based on IRS quarterly rates, currently 7% for non-corporate filers and 6% for corporations, calculated from the date of payment. CBP calculates interest automatically as part of the CAPE process.
What You Need to Have in Place to Receive a Refund
Even if your entries are eligible, there are two account requirements that must be completed before you can receive anything. Neither of these is optional and neither happens automatically.
The first is an ACE Top Account with an Importer sub-account view. ACE is CBP’s Automated Commercial Environment portal at ace.cbp.gov. Having an importer of record number does not automatically give your company access to this system. You need to apply separately. The application requires your Employer Identification Number or importer of record number and a current CBP Form 5106 on file with CBP. CBP sends a verification code to the email address on your 5106 record so that address needs to be current. Processing normally takes 3 to 5 business days but is currently running longer.
The second is ACH electronic refund enrollment. As of February 6, 2026, CBP no longer issues paper refund checks. All refunds are processed electronically. The Trade Account Owner of your ACE account needs to add a U.S. bank account under the ACH Refund Authorization tab inside the Importer sub-account. The bank routing number must support FedACH payments. Non-resident importers need a NACHA-compliant U.S. bank account.
If either of these is not in place when CBP processes your entries, your refund will go into reject status. It is not permanently lost but it does create additional steps and delays to resolve. Completing this setup now while the CAPE system is still being built is the practical thing to do.
What Is CAPE and How Will the Refund Process Work
CAPE stands for Consolidated Administration and Processing of Entries. It is a new system CBP is building specifically to handle IEEPA refunds. It has four components: the Claim Portal, Mass Processing, Review and Liquidation, and the Refund module.
As of March 31, 2026, based on a declaration filed by CBP Executive Director Brandon Lord with the Court of International Trade, development progress stands as follows. The Claim Portal is 85% complete, Mass Processing is 60% complete, Review and Liquidation is 80% complete, and the Refund component is 75% complete.
When CAPE opens, the importer of record or an authorized representative will log into the ACE portal and upload a CSV file of IEEPA-tariffed entry summary numbers through a new CAPE Claim Portal tab. CBP will validate the file, recalculate duties without the IEEPA charges, and issue an electronic refund to the bank account enrolled in the ACE account. CBP has also indicated that refunds will be consolidated by liquidation and reliquidation date and importer of record, or a party the importer of record has formally designated to receive refunds on their behalf.
CBP also confirmed several important updates to Phase 1 scope. Entries with Suspended, Extended, or Under Review status will now be accepted on a CAPE Declaration. CAPE will remove the IEEPA HTS codes from these entries but will not immediately process the refund. Instead, those entries will liquidate in the normal course, and the refund will follow at that time. Warehouse and warehouse withdrawal entries are also now accepted with the same approach. AD/CVD entries will be accepted and IEEPA codes removed, but refunds will not be processed until the Department of Commerce lifts the suspension. CBP will take up to 45 days from accepting a CAPE Declaration to review and liquidate the validated entries. Phase 1 is expected to cover approximately 63% of all entries for which IEEPA duties were paid.
Where Things Stand as of March 31, 2026
On March 20, 2026, Judge Richard K. Eaton issued a new order following a closed settlement conference held March 19. The order expanded the existing refund directive to cover all IEEPA duties including those imposed on imports from Brazil and India, which had not been explicitly included before. The court confirmed CBP is making satisfactory progress on CAPE and ordered CBP to file a progress report by 12:00 p.m. EDT on March 31, 2026. A closed settlement conference was held at 2:00 p.m. the same day. The order requiring immediate compliance remains suspended while CAPE is being built.
On March 27, 2026, the court issued a further amended order resolving the last major open question by directing CBP to reliquidate finally liquidated entries as well, meaning all IEEPA-tariffed entries are now covered by the court order regardless of liquidation status. The order remains suspended while CAPE is being built.
A Note on Liquidated Entries and Protest Deadlines
On March 27, 2026, the Court of International Trade issued its most expansive order to date, directing CBP to reliquidate all entries subject to IEEPA duties without regard to those duties. This now covers three categories: unliquidated entries, entries that have liquidated but where liquidation is not yet final, and entries where liquidation has become final. Previously, finally liquidated entries had been left unresolved, and importers were directed to the protest process. That has now changed. The order continues to be suspended to the extent it requires immediate compliance while CAPE is being built. On March 31, 2026, CBP confirmed that Phase 1 of CAPE will not process finally liquidated entries. CBP stated that to meet the mid-April Phase 1 launch timeline, finally liquidated entries must be deferred to a subsequent phase of CAPE development. The court order requiring their reliquidation still stands and CBP is obligated to address them, but the timing is uncertain. If you have finally liquidated entries, consult a licensed trade attorney about your options while waiting for the subsequent CAPE phase.
Our Free IEEPA Tariff Refund Tools
We built a free resource center to help importers work through this process systematically. None of the tools require an account or signup.
Our main hub page where all tools and guides are available in one place. A good starting point if you are not sure where to begin.
An interactive tool that walks you through a series of questions about your entries and helps you determine whether they may be eligible for CAPE Phase 1, whether a protest may be needed, or whether other circumstances apply. Takes about two minutes to complete.
A calculator that takes your import dates and walks you through the relevant deadlines for your situation including protest windows, expected liquidation dates, and the CAPE filing timeline. Supports up to 50 entries at once.
A 16-step checklist across four categories covering everything you need to have in place before the CAPE portal opens. Tracks your progress as you work through it.
A plain language guide to customs liquidation covering what it means, the different liquidation statuses, how the 180-day protest deadline works, and how liquidation status affects your CAPE eligibility. Available as a step-by-step walkthrough and a quick reference table.
A full interactive timeline of every major development in the IEEPA tariff situation from the first executive orders in February 2025 through today. Click any event for full details. Updated regularly as new court filings, CBP declarations, and other developments occur.
What to Do Right Now
Here is a straightforward summary of steps worth taking now while CAPE is still being built.
Step one: Confirm whether your company has an active ACE Top Account with an Importer sub-account view at ace.cbp.gov If not, apply now as processing times are currently longer than usual.
Step two: Once your ACE account is confirmed active, verify that ACH electronic refund enrollment is complete under the ACH Refund Authorization tab in your Importer sub-account.
Step three: Compile your entry records for shipments from February 4, 2025, through February 24, 2026. You will need entry summary numbers, IEEPA HTS codes, duty amounts paid, and the current liquidation status of each entry. Your customs broker can assist with pulling this information from ACE.
Step four: Use our free tools to review your eligibility, check relevant deadlines, and work through the CAPE readiness checklist.
Step five: When CAPE launches, be prepared to file promptly. There is no benefit to waiting once the portal opens.
If any of your entries have already liquidated or carry a complex status, review your situation with a licensed customs broker or trade attorney before relevant deadlines pass.
How Southern Star Navigation Can Help
Southern Star Navigation has been following the IEEPA refund process closely and built these free resources to help our partners.
Visit our IEEPA TARIFF REFUND RESOURCES page to access all of our free tools or contact us directly to discuss your specific situation.
Disclaimer: This article is for informational purposes only. It is not legal or financial advice. For guidance specific to your entries and situation, contact a licensed customs broker or trade attorney.
Sources
Supreme Court opinion, Learning Resources, Inc. v. Trump (February 20, 2026)
Declaration of Brandon Lord, Executive Director, Trade Programs, U.S. Customs and Border Protection, Court of International Trade Case No. 26-01259, Document 47 (March 19, 2026)
Declaration of Brandon Lord, Court of International Trade Case No. 26-01259, Document 39 (March 12, 2026)
Declaration of Brandon Lord, Executive Director, Trade Programs, U.S. Customs and Border Protection, Court of International Trade Case No. 26-01259, Document 51 (March 31, 2026)
Order, Atmus Filtration, Inc. v. United States, Court of International Trade Case No. 26-01259, Document 49 (March 20, 2026)
Order, Atmus Filtration, Inc. v. United States, Court of International Trade Case No. 26-01259, Document 50 (March 27, 2026)
U.S. Customs and Border Protection, ACE Portal and ACH Refunds FAQs: https://www.cbp.gov/trade/automated/ace-portal-and-ach-refunds-faqs
U.S. Customs and Border Protection, Applying for an ACE Secure Data Portal Account: https://www.cbp.gov/trade/automated/how-to-use-ace/portal-applying
Federal Register, Quarterly IRS Interest Rates Used in Calculating Interest on Overdue Accounts and Refunds of Customs Duties: https://www.federalregister.gov/documents/2025/07/01/2025-12241/quarterly-irs-interest-rates-used-in-calculating-interest-on-overdue-accounts-and-refunds-of-customs
