Status: The Supreme Court struck down the IEEPA tariffs (February 2026). Refunds run through CBP’s CAPE process, with Phase 1 covering unliquidated entries and entries within 80 days of liquidation. Last reviewed June 2026.
The short version
You generally qualify for an IEEPA tariff refund if you paid IEEPA-related duties as the importer of record on eligible entries. The three things that decide eligibility are whether the duties were actually IEEPA-related (and not Section 232 or 301, which are not refundable), whether you are the party entitled to the refund, and which CAPE phase the entry falls into. Goods type and dollar amount do not decide eligibility on their own.
Were the duties actually IEEPA-related?
Confirm the tariff basis on the entry summary rather than assuming from the commercial invoice. An entry can carry several duty types at once, and only the IEEPA-related portion is in scope for these refunds. Your entry/duty report is the document that shows this cleanly.
Are you the party entitled to the refund?
The refund normally goes to the importer of record. On DDP shipments, where a foreign seller arranged delivery and duties, or on certain courier entries where a carrier acted as importer of record, the entitled party can be someone other than the company that “felt” the cost. Determining the importer of record correctly is often the difference between a clean refund and a stalled one.
Is the entry still actionable?
An entry that is unliquidated, or that liquidated within the past 80 days, is a CAPE Phase 1 candidate. Entries that liquidated earlier fall to later CAPE phases — the Court of International Trade has addressed refunds for entries with final liquidations, so they are not automatically lost. A Form 19 protest, within its 180-day window, remains a parallel route for issues outside CAPE. This is why the first practical step is always sorting entries by liquidation date — see the deadlines guide.
Frequently asked questions
I paid the duties but I’m not the importer of record. Can I claim?
Typically the importer of record is the party that can claim, even if another company bore the cost commercially. Where you paid duties under a DDP arrangement but were not the importer of record, recovery often depends on coordination with the party that was. Check the entry to confirm who the importer of record actually is.
Do small importers qualify?
Eligibility does not depend on size. The same rules apply whether you have a handful of entries or thousands. For smaller volumes the practical question is usually whether the recovery is worth the filing effort, not whether you qualify.
Are AD/CVD entries eligible?
Entries subject to antidumping or countervailing duties are commonly handled separately and have frequently been outside the current CAPE phase. They are not necessarily unrecoverable — they may be addressed through a different process or a later phase.
Related guides
- The complete guide to IEEPA tariff refunds
- How to file a CAPE declaration
- IEEPA refund deadlines: how the windows work
Easy Logistics is an independent resource and is not affiliated with U.S. Customs and Border Protection. This is general information as of June 2026, not legal advice. Eligibility and importer-of-record questions should be confirmed with a licensed customs broker or trade attorney for your specific entries.