The IEEPA Tariff Refund Process Has Begun: Eligibility, Timelines, and FAQs
On April 20, U.S. Customs and Border Protection (CBP) opened up the first phase of the process for importers to obtain refunds for tariffs paid under the International Emergency Economic Powers Act (IEEPA). Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation.
The CBP system, known as Consolidated Administration and Processing of Entries (CAPE), has been working to date. According to an April 28 CBP filing with the Court of International Trade (CIT), 47,315 CAPE declarations have been successfully submitted, representing 11,222,927 entries. A total of 2,124,394 entries were rejected for failing the entry-specific validations. Out of the 11,222,927 accepted entries that were successfully submitted, approximately 1,740,000 entries have been liquidated and are in the refund process. Refunds are expected to be processed within 60-90 days after a successful submission.
Only the Importer of Record (IOR) or the licensed customs broker who filed the original entries can file a CAPE Declaration. The CAPE Declaration only consists of the list of entries for which refunds of IEEPA duties are being requested. No other information is required. The Importer of Record (IOR) or licensed customs broker must be enrolled to receive electronic refunds. There will be no paper refund checks.
Future phases will include other types of entries: Entries that have been flagged for reconciliation, as well as Entry Type 09 - Reconciliation Summary; Entries designated on a drawback claim; Entries covered by an open protest; Entries not filed in ACE, and entries without a liquidation status in ACE; and Entries for which liquidation is final. CBP has not yet announced the timeline for future phases.
CBP has created a detailed set of frequently asked questions (FAQs), which CBP is updating often.
Please contact TGA’s Nate Herman at [email protected] if you have any questions or would like additional information. And please join us for the session on tariffs at the TGA Show in Salt Lake City on June 23-25.
Additional Update for TGA Members: Survey for Business Owners on Tariff Impacts
The We Pay the Tariffs small business coalition is conducting a survey on tariff impacts, the IEEPA refund process, and future tariff expectations. Responses will be used to create a report including both quantitative benchmarking results and company anecdotes. No company-specific information will be published without explicit permission.
We strongly encourage impacted small businesses to participate to ensure TGA members’ experiences and concerns are reflected in the final report. The coalition believes the report could be particularly useful in pushing back on the narrative that refunds should go to consumers rather than importers.
We Pay the Tariffs is seeking responses by May 15 at the following link: www.wepaythetariffs.com/april-2026-sb-survey
Questions about the survey can be directed to Dan Anthony, Executive Director of We Pay the Tariffs, at [email protected].