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un-tariff / IEEPA Refund
FAQ · Form FAQ-01

IEEPA refund, answered.

Every question importers have asked us during onboarding, organized by topic. Can't find yours? Contact us and we'll add it.

Eligibility

Who can file for an IEEPA refund?
The importer of record (IOR) on the entry. If a broker filed on your behalf, the IOR is still you — the refund is paid to the IOR's ACH account, not the broker's. See the IEEPA refund overview for eligibility specifics.
What dates count as IEEPA entries?
Entries with a filing date between Feb 1, 2025 and Feb 7, 2026 that paid duties under an IEEPA-issued executive order. Entries outside this window, even if they paid tariffs, are not IEEPA entries and are not refundable via CAPE.
I paid Section 232 and Section 301 — are those refundable too?
No. Section 232 and Section 301 are different statutes that give the President explicit tariff authority. The SCOTUS ruling in Learning Resources only invalidated IEEPA. If an entry stacked IEEPA on top of Section 232 or 301, only the IEEPA portion refunds.
My entry is past the 80-day cliff — what can I do?
CAPE won't accept it. Recovery moves to a formal protest under 19 CFR 174, with a 180-day liquidation-date clock. See the 80-day cliff guide. Protest is out of scope for un-tariff Phase 1.
Do I need to have been the one who physically paid the duty?
No. The refund goes to the importer of record, regardless of who remitted the duty to CBP. If your broker fronted the duty and billed you, you are still the IOR and still the refund recipient.

Filing mechanics

What format does CAPE require?
A UTF-8 CSV with one column — 11-character CBP entry numbers (3-char filer code + 7-digit serial + 1 check digit) — with the required header row from CBP's CAPE Upload Template, LF line endings, maximum 9,999 rows. Upload via the ACE Portal. CBP's back office does the principal computation and the interest walk.
Do I need a customs broker to file?
No. CAPE accepts filings directly from the IOR through the ACE Portal. A broker can file on your behalf if you prefer. The mechanical work is preparing a validated CSV, not making a legal argument.
How many CAPE declarations can I file?
Unlimited. Each is capped at 9,999 entries, but there's no cap on the number of declarations per IOR. If you have 12,000 entries, file two declarations.
How long does CBP take to pay?
CBP's posted service level is 60–90 days from accepted declaration to ACH deposit. The first wave of Q2 2026 filings is expected to run longer due to volume.
What if CBP rejects my filing?
CBP returns a validation error list keyed to the VAL-F/E/I rule that failed. Fix the offending rows and resubmit. un-tariff runs CBP's validation locally before download, so most rejections are environmental (wrong ACH payer ID, expired filer code), not content errors. See the complete CAPE filing guide.

Interest and amounts

How is interest calculated?
CBP pays the quarterly overpayment rate published under 19 CFR 24.3a, compounded daily from the date you paid the duty to the date CBP issues the refund. At Q2 2026 rates, that's approximately 8% annualized.
Can I see the exact interest number before I file?
un-tariff computes expected principal and interest per entry before you file, using the published quarterly rate table. CBP may vary by a small amount at reconciliation time — usually within 1% due to exact-day timing differences.
What is a typical refund?
There is no typical. IEEPA duty was 7.5%, 10%, 15%, 20%, or 25% depending on the tranche. A mid-size importer with $500K of IEEPA-dutiable value across the window recovers in the high five figures with interest. Use the free calculator for a band specific to your numbers.

Edge cases

What about USMCA exclusions?
Entries originating from Canada or Mexico that qualified for USMCA preferential treatment were excluded from some IEEPA tranches. If your entries are USMCA-qualifying but were charged IEEPA anyway, rule IEEPA-006 in un-tariff's classifier flags them; CBP may process the refund with a correction rather than the straight CAPE amount. Talk to a customs attorney for edge cases.
What about tariff stacking?
Stacking is when the same entry line paid both IEEPA and Section 232 or Section 301. Only the IEEPA portion refunds. un-tariff's stacking rule IEEPA-005 separates the buckets per-line. CBP's CAPE validation will reject a file that claims stacked amounts.
I already protested before CAPE opened — do I need to file CAPE too?
If your protest is pending, no — the protest covers the claim. If your protest was denied, ask counsel about re-filing through CAPE if the entry is still within the 80-day window. If both channels collect the same entry, CBP deduplicates.

The product

What does un-tariff actually do?
Given your ACE Entry Summary export, un-tariff classifies every line against CBP's Chapter 99 IEEPA registry, separates stacked Section 232/301 amounts, computes principal and interest per entry, checks the 80-day cliff, runs all CBP VAL-F/E/I validation rules locally, and generates a CAPE-ready CSV for you to upload to the ACE Portal.
Is un-tariff a customs broker?
No. un-tariff is software. It prepares the filing; you submit it to CBP yourself through the ACE Portal. This keeps the price flat (see pricing) rather than a broker's percentage-of-refund fee structure.
Is un-tariff legal advice?
No. Classification disputes, exclusion arguments, and protest strategy are legal matters and require counsel. un-tariff handles the administrative mechanics of a straightforward CAPE filing.
How is pricing structured?
Flat fee by refund size. Pay once, file once. No subscriptions, no per-entry charges, no percentage of your refund. See pricing for the three tiers.
What happens to my data?
Entry data is processed server-side, stored encrypted, and not shared with third parties outside the classification pipeline. See the privacy policy and DPA for specifics.