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Guide · US customs

IEEPA tariff refunds: who can claim, how CAPE works and the deadlines

Updated · Rotomal

The importer of record can claim a refund of IEEPA tariffs paid between 1 February 2025 and 23 February 2026 by uploading a CAPE declaration, a CSV of entry numbers, in the CAPE tab of the ACE Portal. CAPE accepts entries that are unliquidated or no more than 80 days past liquidation. Older, finally liquidated entries are currently refunded through CAPE only for importers that sued at the Court of International Trade and whose importer number reached CBP by 30 July 2026; for others, a protest within 180 days of liquidation or legal action may be the remaining routes.

Timeline

DateWhat happened
1 Feb 2025 – 23 Feb 2026IEEPA tariffs collected on imports
20 Feb 2026Supreme Court rules 6–3 in Learning Resources v. Trump that IEEPA does not authorize tariffs
20 Apr 2026CAPE Phase 1 opens: unliquidated entries and entries up to 80 days past liquidation
29 Jun 2026Phase 2 opens: entries flagged for reconciliation, unliquidated or within 80 days of liquidation, where the reconciliation entry is not yet filed
6 Oct 2026Phase 3 opens for finally liquidated entries, limited to CIT plaintiffs whose importer number reached CBP by 30 July 2026

Which route fits each entry

Entry status todayRouteWatch out for
Not yet liquidatedCAPE declaration in ACEIt will liquidate; file before it ages out
Liquidated up to 80 days agoCAPE declaration in ACEACE rejects it once it passes 80 days
Flagged for reconciliationPhase 2 rulesNot accepted in a normal CAPE declaration
More than 80 days past liquidationCAPE only for CIT plaintiffs; otherwise protest or legal actionProtest generally due within 180 days of liquidation

Steps to file a CAPE declaration

  • Make sure your business has an ACE Portal account with importer access, or that your broker will file for you.
  • Put refund bank details on file with CBP: refunds are paid by ACH.
  • List the entry numbers with IEEPA duties, using the importer number on each entry summary.
  • Download the CAPE upload template from the CAPE tab, put one entry number per row under the Entry Number header and save as CSV.
  • Tick the Acknowledge box, which confirms you are legally authorized to make the filing, upload the file and check its status in the File Upload History and Claim Status subtabs.
  • Fix rejected entries from the validation result file and upload only those again.

If a courier cleared your parcels

Most small online sellers never filed an entry themselves: UPS, FedEx or DHL filed it and billed the duty afterwards. Your business is often still the importer of record; the importer number on the entry summary shows who is. CAPE can be filed from the importer's own ACE account, or by the broker that filed the entries from its broker account. Either way you need the entry numbers, which appear on courier duty invoices and statements.

If you want help

Refund Ledger builds the entry-by-entry list from your ACE reports or courier invoices, shows the date each entry's CAPE window closes, and lays out the entry list in CAPE template format for you to review and upload. A $19 deadline check for 25 entries, credited against the ledger, then $149 once for up to 300 entries. It organizes your records; it is not legal advice or customs brokerage, and you or your licensed broker file.

Questions

Is there a deadline to file a CAPE declaration?

There is no single date. Each entry stops qualifying for CAPE, for importers who have not sued, once it is more than 80 days past its liquidation date.

How long does a refund take?

CBP has said valid refunds are generally issued within 60 to 90 days after the CAPE declaration is accepted, unless an entry needs further review.

Does CBP charge a fee?

No. CBP does not charge for processing tariff refunds.

Sources

Guides and answers