What the IEEPA refund is
Between February 1, 2025 and February 7, 2026, US Customs and Border Protection (CBP) collected duties on thousands of import lines under tariffs issued by executive order, citing the International Emergency Economic Powers Act (IEEPA). On February 20, 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump that the President did not have IEEPA authority to impose those tariffs. The duties were collected under an invalid legal basis. The money owes back.
CBP stood up a new refund channel — the CAPE system (Centralized Ad-hoc Payment / Entry refund channel) — that became the exclusive path for IEEPA refunds on April 20, 2026. CAPE accepts a CSV-format declaration, one row per entry, containing the entry number and nothing else. CBP's back office does the principal calculation, applies CBP interest at the published quarterly rates, and issues the refund via ACH.
The free calculator on this site gives you a rough refund band in under two minutes. No account, no CSV, no signup.
Who qualifies
Three conditions, all of which must be true:
- You were the importer of record on the entry. Customs brokers who filed on your behalf do not receive the refund — you do.
- The entry was filed between Feb 1, 2025 and Feb 7, 2026 — the IEEPA window. Entries before or after fall under different tariff regimes (Section 232, Section 301, normal column-1 duties) and are not IEEPA.
- The entry has not passed the 80-day cliff. CBP's CAPE rules require the claim to be filed within 80 days of the liquidation date, not the entry date. If liquidation is more than 80 days in the past, the claim has to go through protest instead — a separate process with a different 180-day clock.
How much
Two components:
Principal
The IEEPA portion of the duty you paid. For most lines this is a straightforward percentage of the dutiable value, keyed to the executive order in effect on the entry date and the HTS subheading. The rate was 7.5%, 10%, 15%, 20%, or 25% depending on the tranche. Some HTS codes had tariff stacking — IEEPA on top of Section 232 or Section 301 — and require careful separation of what's refundable (IEEPA only) from what's not (Section 232/301 stay intact).
Interest
CBP pays interest on refunded duty at the quarterly overpayment-interest rate, compounded daily from the date you paid the duty (or the liquidation date, whichever applies under the specific rule) to the date the refund is processed. At current rates, that's roughly 8 percent annualized. For a line item paid in Q3 2025, a refund in Q2 2026 adds about 6 percent to the principal.
A typical mid-size importer with $500k of IEEPA-tranche duties across the window recovers in the high-five-figure range once interest is compounded. Your number depends on what you actually imported and when you paid.
Why CAPE and not a protest
CBP explicitly created CAPE for this wave. Unlike a Form 19 protest — which requires legal arguments, supporting documentation, and a formal hearing track — CAPE is a CSV. CBP runs the classification and the interest walk on its side. You submit entry numbers; they send money.
The catch is eligibility. CAPE is bounded by the 80-day post-liquidation cliff. Past that point, CAPE refuses the entry and you're back on the protest path, which means hiring counsel or a broker and arguing for relief — fundamentally different workflow, different cost structure.
This is why timing drives everything. See the 80-day cliff guide for how liquidation dates work and how to figure out which of your entries are still in the CAPE window.
What a CAPE filing actually contains
A CAPE declaration is a CSV file with exactly one column — the 11-character CBP entry number — and up to 9,999 rows per file. That's it. CBP's side already has the entry summary, the paid duty breakdown, the HTS classifications, and the interest table. The CSV is a pointer into data CBP already holds.
The hard part is knowing which of your entries to put in the file. That's where the ACE Entry Summary export comes in — you pull the full entry list from the ACE Portal, classify each entry against the CBP Chapter 99 IEEPA HTS registry, check the liquidation cliff, drop the ineligible ones, and ship the remainder as a CAPE CSV.
See the complete CAPE filing guide for every CBP VAL-F and VAL-I rule the CSV has to pass before the Portal will accept it. un-tariff runs all of those checks locally before you download, so a failed upload isn't something you discover at 10pm on day 79.
Common questions
Who qualifies for an IEEPA refund?
Any US importer of record who paid IEEPA-classified duties on entries filed between Feb 1, 2025 and Feb 7, 2026, provided the entries have not passed the 80-day post-liquidation cliff. If your entries were Section 232 or Section 301 only, they are not IEEPA and not in scope for the CAPE refund channel.
How much can I recover?
You get back the IEEPA portion of the duty plus CBP interest at the published quarterly rates, compounded daily from the date of payment to the refund date. The principal is usually 7.5 to 25 percent of the dutiable value depending on the HTS classification and the executive order in effect when the entry was filed. Run the free calculator for a rough band.
Is this a class action or a settlement?
No. This is the normal CBP refund process, triggered by the Supreme Court's Feb 20, 2026 ruling. CBP opened the CAPE system on Apr 20, 2026 as the exclusive channel for IEEPA refunds. Each importer files their own claim.
Do I need a customs broker to file?
No. CAPE accepts a CSV-format declaration that any importer of record can prepare and upload through the ACE Portal. A broker can file on your behalf if you prefer, but the mechanical work is a validated CSV, not a nuanced legal argument.
What happens if I miss the 80-day cliff?
Entries past 80 days from liquidation are not eligible for CAPE. Recovery then requires a formal protest (19 CFR 174) within 180 days of liquidation, which is a heavier process and typically warrants counsel. un-tariff Phase 1 does not handle protests.