If you imported goods into the United States in 2025 or 2026 and paid IEEPA tariffs, you may be owed a refund. In February 2026, the Supreme Court struck down the use of IEEPA — the International Emergency Economic Powers Act — as legal authority for imposing tariffs. That ruling turned billions of dollars in duties into one of the largest refund programs in U.S. history, and the money flows through CBP’s CAPE system (the Consolidated Administration and Processing of Entries) inside the ACE portal, which launched April 20, 2026.
Then, on October 6, 2026, CBP expanded the program again with Phase 3. This round covers finally-liquidated entries — the oldest, most settled entries in the system. But there’s a catch, and it’s a big one. Here’s who qualifies right now, how to file, which tariffs you can’t get back, and what refund scammers want you to miss.
What’s actually happening: the numbers
The scale of this refund program is hard to overstate. Roughly 330,000 importers paid about $166 billion in IEEPA duties across some 53 million entries. By May 22, 2026, CBP had certified $20.6 billion in refunds, and total refund potential could reach up to $85 billion as the program moves through its phases.
For a small business that imports inventory, components, or finished goods, this isn’t pocket change. A refund could recover a season’s worth of margin — plus interest, because CBP pays interest on the duties you’re getting back.
Phase 1: the entries that qualified first
The first phase of the program covered the cleanest cases: unliquidated entries, plus entries that were liquidated within 80 days. If your entries sat in either bucket, the path has been straightforward since CAPE launched — submit a declaration, get validated, get paid.
Declarations are filed in bulk through CSV uploads, with up to 9,999 entries per declaration. That matters for small importers too: if you’ve got a few hundred entries across a year of shipments, you can package them in a handful of declarations instead of filing one by one.
Refunds typically arrive 60 to 90 days after your declaration is accepted — and they come with interest on the duties you paid. CBP charges no processing fees for the refund itself.
Phase 3 (October 6, 2026): finally-liquidated entries open up — with strings attached
This is the October 6, 2026 expansion, and it’s the big news for importers whose entries are old enough to be fully settled. Finally-liquidated entries are now eligible — but only for importers who meet both of these conditions:
- You submitted a valid Importer of Record number to CBP by July 30, 2026.
- You are a plaintiff in a pending CIT (Court of International Trade) IEEPA case.
If you meet both conditions, your finally-liquidated entries have an administrative refund path. If you don’t — and that includes most small importers who never entered litigation — there is currently no administrative path for your finally-liquidated entries. That’s the honest read: Phase 3 is real progress, but it’s narrowly gated.
This Supply Chain Dive report lays out the timeline and the conditions. It’s worth reading if your entries fall in this older category and you’re trying to figure out where you stand.
What you can’t get back
Not every tariff you paid is an IEEPA tariff, and this part trips people up. Here’s what’s NOT refundable:
Section 232 tariffs — these stay in place: steel at 50%, aluminum at 50%, autos at 25%, copper at 50%, semiconductors at 25%, and lumber at 10%. These were imposed under national-security authority, not IEEPA, so the Supreme Court ruling doesn’t touch them.
Section 301 tariffs on China — also stay, running 25% to 100% depending on the product category.
The base reciprocal tariff — the 10% tariff imposed under Section 122 expired July 24, 2026, and it was replaced by a separate, still-active Section 301 tariff targeting forced labor. It’s not part of the IEEPA refund program either.
Before you spend time filing, separate your entry records by tariff authority. You want the IEEPA lines — everything else is staying where it is.
The deadlines that decide your case
Timing is everything in customs, and these refunds are no exception. The single most important number: 180 days from liquidation. Under 19 U.S.C. 1514, you have 180 days from the date an entry is liquidated to file a formal protest.
That creates three distinct situations:
- Within 80 days of liquidation: you’re in the simplest lane — the Phase 1 administrative path through CAPE.
- Past 80 days but within 180 days: the formal protest path is your route. This is still administrative, but it requires the protest filing, not just a declaration.
- Past 180 days: you’ve missed the protest window. At this point, your only route is litigation at the Court of International Trade.
Don’t guess at your dates. Pull your liquidation dates from your ACE records, or ask your customs broker for a liquidation report, before you decide which path you’re on.
How to file: five steps
Whether you’re filing a declaration or a protest, the setup work is the same. Here’s the order of operations:
1. Update your CBP Form 5106 importer record. Make sure the record carries your own company email — not your broker’s. CBP communicates about your refund through this record, and missed emails mean missed deadlines.
2. Create an ACE portal account. If you don’t have one, start now: setup can take 3 to 4 weeks. You can’t file or track anything without it.
3. Enroll in ACH Refunds. This is how CBP deposits your refund directly into your bank account instead of mailing a check into the void. Make sure the account you enroll is one you trust with large incoming deposits — if your current business account isn’t cutting it, compare your options among the best business checking accounts for freelancers and small businesses before you enroll.
4. Submit your CAPE declaration via CSV upload. You can file directly as the importer — the system is designed to allow it. But realistically, for more than a handful of entries, use a customs broker. A single mistyped entry line can stall a whole declaration, and brokers do this at volume.
5. Track validation and payment in the CAPE tab. Once your declaration is in, you can watch it move through validation toward payment inside the ACE portal. This is also where you’ll spot problems — a rejected line, a mismatched entry number — before they cost you months.
One more practical tip: treat the expected refund as a receivable in your books from the moment your declaration is accepted, not from the day the money lands. If you’re running your own books, the best accounting software for freelancers and small businesses will let you record it properly so your cash-flow forecasts reflect the money that’s on its way.
For a detailed walkthrough of the claim mechanics, this step-by-step IEEPA refund guide covers the filing process in depth.
Who actually gets the money
The refunds go to the Importer of Record only. That’s the entity named on the customs entry — usually you, if you import directly, or your supplier’s U.S. entity if you buy through one.
If you’re a consumer wondering whether you’ll get a check: no. There are no direct refunds to consumers. Any benefit for shoppers shows up as gradual pricing changes through 2026 and 2027 as importers pass through some of the recovered costs. Whether your favorite store actually lowers prices is their decision, not a requirement.
One consequence worth knowing: if you imported through a distributor or wholesaler who was the Importer of Record, the refund goes to them. You’d need to negotiate any pass-through with them yourself — CBP won’t do it for you.
Watch out for refund scams
When tens of billions of dollars start moving, the scammers arrive on schedule. The U.S. Chamber of Commerce has warned that fraudsters are actively targeting small importers with refund pitches — cold calls, cold emails, and lookalike websites offering to “handle your IEEPA claim.”
A few rules to protect yourself:
- Never pay upfront to “unlock” a refund. CBP charges no processing fees, and legitimate filing costs you nothing beyond your broker’s normal rate.
- Push back on percentage-of-refund contingency fees for copy-paste CIT litigation. One advisor site recommends exactly this — and prefers hourly quotes instead. A boilerplate court filing isn’t worth a cut of your recovery.
- Verify who you’re talking to. Real brokers have a customs broker license number and a track record. If someone contacted you out of nowhere and wants your ACE credentials, that’s not a broker — that’s a problem.
The short version: if a deal sounds like free money handled by a stranger, it’s bait. Your importer record, your ACE account, and your broker are the only parties that should touch this process.
Frequently Asked Questions
Do I need a lawyer to get my IEEPA tariff refund?
No — not for the standard administrative path. You can file a CAPE declaration yourself through the ACE portal, or have your customs broker do it. A lawyer or trade counsel becomes necessary only if you’re past the 180-day protest window and need to go to the Court of International Trade.
How long does it take to get the refund?
Refunds typically arrive 60 to 90 days after your declaration is accepted, with interest on the duties paid. Build your cash-flow plans around the longer end of that range — customs timelines slip.
Can I file for entries that are already finally liquidated?
Only under the Phase 3 conditions that took effect October 6, 2026: you must have submitted a valid Importer of Record number to CBP by July 30, 2026, and be a plaintiff in a pending CIT IEEPA case. If either condition is missing, there’s currently no administrative path for your finally-liquidated entries.
What if my broker filed my entries under their own information?
You still qualify as long as you were the Importer of Record. But make sure your CBP Form 5106 record now carries your own company email, and confirm with your broker exactly which entries were filed in your name versus theirs.
Does the refund include interest?
Yes. Refunds are paid with interest on the duties you paid — which is one more reason to file promptly rather than letting the money sit with CBP.
Are Section 232 steel and aluminum tariffs included?
No. Section 232 tariffs (steel 50%, aluminum 50%, and the rest), Section 301 tariffs on China (25–100%), and the expired base reciprocal tariff are not part of the IEEPA refund program.
This article is for informational purposes only and isn’t legal or tax advice. Tariff refund rules involve real deadlines and real money — confirm your situation with your customs broker or trade counsel before you file.