How to Claim Your IEEPA Tariff Refund Before the Deadline

A lot of brands are asking the same question right now: can we get our tariff money back?

In many cases, yes. But the refund window is limited, the filing path depends on the status of each customs entry, and not every tariff program was struck down. If you're an importer who paid duties under IEEPA, here's what you need to know to act before the clock runs out.

What the Court Actually Decided

On February 20, 2026, the U.S. Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize broad presidential tariffs. That ruling followed an earlier decision from the U.S. Court of International Trade on May 28, 2025. You can read the Supreme Court opinion directly, and CBP's official IEEPA duty refunds page has been updated to reflect the refund process.

The key distinction worth repeating clearly: the court did not say all tariffs are illegal. It said IEEPA was not a valid legal basis for sweeping presidential tariffs. Other tariff programs, including Section 232 and Section 301, were not touched by the ruling and remain in effect.

The clean takeaway:

• Some IEEPA-based duties may now be refundable.
• Other tariff authorities are still fully active.

Key Terms Every Importer Should Know

If this process feels like alphabet soup, start here.

• ‍IEEPA stands for International Emergency Economic Powers Act. That is the statute the government used to justify the broad tariffs at issue in the case.‍
• ACE stands for Automated Commercial Environment. This is CBP's main trade portal and customs data system. Importers and brokers use it to review entries, file corrections, and access the refund process. CBP's overview is on the ACE Portal page.‍
• CAPE stands for Consolidated Administration and Processing of Entries. This is CBP's ACE-based refund tool built specifically for eligible IEEPA claims. Phase 1 opens on April 20, 2026. CBP's launch notice is available in the official CBP trade information notice.‍
• Liquidated vs. unliquidated entries: A liquidated entry means CBP has made its final duty calculation on that shipment. An unliquidated entry is still open and not yet finalized. That distinction determines how you file and how much time you have.

Who Can Actually File for a Refund

The party CBP recognizes is the Importer of Record.

Refunds go to the importer listed on the entry, not necessarily to your brand. So if your customs broker, freight forwarder, or another party filed under a different importer number, the refund path may run through that party first. Before you assume a refund belongs directly to your company, confirm who actually filed each entry. That step alone can save a lot of confusion later.

When the Filing Window Opens (And Why Timing Matters)

CAPE Phase 1 filing begins April 20, 2026 through the ACE Secure Data Portal. CBP's current Phase 1 scope covers certain unliquidated entries and certain entries within 80 days of liquidation.

However, the broader deadline picture is more nuanced, and this is the part brands cannot afford to ignore.

• Unliquidated entries: A Post Summary Correction (PSC) can be filed within 300 days of the date of entry, or up to 15 days before scheduled liquidation, whichever comes first.
• Liquidated entries: The standard challenge path is a customs protest, which generally must be filed within 180 days of liquidation.
• CAPE Phase 1: Currently limited to certain unliquidated entries and entries within 80 days of liquidation.

Every entry has its own clock. Missing a deadline can permanently forfeit the refund, even if the underlying tariff was invalid.

How to File for an IEEPA Tariff Refund

The process is manageable if you approach it methodically. Here's the framework:

Step 1: Pull your entry list from ACE. Sort each entry by date, entry number, importer of record, and liquidation status.

Step 2: Triage each entry into the right bucket:

• Use CAPE for eligible Phase 1 entries through the ACE Portal.
• Use a PSC for unliquidated entries still within the correction window.
• Use a customs protest for liquidated entries still within the 180-day protest deadline.

Step 3: Confirm your ACH banking information is on file in ACE. CBP issues refunds electronically, so if your banking details aren't current in the system, payment will be delayed.

That framework covers the majority of cases. Complex scenarios, especially older liquidated entries or situations where the importer of record question is unclear, may benefit from a trade attorney's review.

Do You Need an ACE Account?

In most cases, yes.

CBP's entire refund process runs through ACE, and CAPE is only accessible through the ACE Secure Data Portal. If you or your broker don't have the right ACE permissions set up, that's the first thing to fix. CBP's setup process is outlined on the ACE getting started page.

Who to Call First

Start with your customs broker. They can usually pull your full entry history, identify liquidation status for each entry, and recommend whether each claim belongs in CAPE, PSC, or protest.

If the importer of record situation is complicated, or if you're dealing with older liquidated entries, a trade advisor or customs attorney is worth the call. Don't wait until a deadline is days away.

The Bottom Line

The 2026 IEEPA ruling created a real refund opportunity for many importers. But it did not create a simple, automatic process. Brands still need to know which entries are affected, who the importer of record is, whether entries are liquidated or unliquidated, and which deadline applies.

Waiting is the one thing you cannot afford to do. Pull your ACE entry list now, sort entries by status, and get your broker or advisor reviewing them immediately.

Frequently Asked Questions

Are tariff refunds automatic after the Supreme Court ruling?

No. Refunds are not automatic. Importers need to identify eligible entries, determine the correct filing path (CAPE, PSC, or protest), and meet the applicable deadline. CBP requires active filing through its refund program.

What is the difference between CAPE and a PSC?

CAPE is CBP's new ACE-based refund tool built specifically for eligible IEEPA duty claims. A Post Summary Correction (PSC) is the standard correction method for unliquidated entries before CBP finalizes them. CAPE is specific to the IEEPA refund rollout. PSC is a broader customs correction tool that applies in other contexts as well.

What happens if I miss the filing deadline?

In most cases, you lose the refund opportunity permanently. That is why reviewing your entry list now, rather than waiting for CBP to sort it out automatically, is so important. There is no general grace period.

What if I'm not the Importer of Record on the entry?

If another party (your broker, forwarder, or a third party) is listed as the Importer of Record, the refund may be directed to them first. Confirm who filed each entry in ACE before assuming the refund flows directly to your company.

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