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IEEPA tariff refunds: where things stand

Who can get back the IEEPA duties paid in 2025 and early 2026, how CBP's CAPE refunds work, what the class action of October 2026 changes, and what to do now.

From February 2025, the United States imposed duties under the International Emergency Economic Powers Act (IEEPA): first on goods of Canada, Mexico and China, then the "reciprocal" duties on goods of most countries, and duties on goods of Brazil and India. After the Supreme Court's decision of February 20, 2026 against these duties, CBP stopped collecting them after February 23, 2026, and the importers who paid them can get them back, with interest. Here is where things stand on October 30, 2026. It is general information, not legal advice: your customs broker or a trade lawyer can say what applies to your entries.

Refunds go through CAPE

US Customs and Border Protection (CBP) refunds IEEPA duties through CAPE (Consolidated Administration and Processing of Entries), a function of its ACE system that groups refunds instead of treating each entry apart:

  • Who files: only the importer of record, or the licensed customs broker who filed the entries, through the ACE Portal, with a list of entry numbers (a CAPE Declaration). An attorney cannot file it for you.
  • Which entries, today: entries not yet liquidated or liquidated within the last 80 days, and entries flagged for reconciliation whose reconciliation entry is not yet filed.
  • Not yet: entries whose liquidation is final (more than 80 days ago), entries under an open protest or on a drawback claim, warehouse entries and some others. CBP lists them as future deployments, without a date.
  • Payment: by electronic transfer (ACH) only, to the refund bank account registered in the ACE Portal, which is separate from the account used to pay CBP. Without it, the refund waits. Interest is included.
  • Timing: CBP says valid refunds are generally issued within 60 to 90 days of the declaration's acceptance; ACE reports (ES-022, REV-603, REV-615) follow each refund.

CBP's IEEPA duty refunds page ↗ has the details and its latest changes.

Finally liquidated entries and the class action

Most entries of 2025 are now finally liquidated, and for them the road depends on whether the importer went to court:

  • Importers who sued at the Court of International Trade have, since October 6, 2026, been given access to CAPE for their finally liquidated entries, on a rolling basis.
  • Importers who did not sue: on October 8, 2026, the Court of International Trade certified a class of the importers of record who paid IEEPA duties between February 1, 2025 and February 19, 2026, other than those who sued on their own (Freestyle World, Inc. v. CBP). Their refunds on finally liquidated entries remain on hold while the government's appeal is pending. The duties specific to Brazil and to India are outside this class.

What to do now

  1. List your entries that paid IEEPA duties, with your broker or from ACE's entry summary reports, such as ES-003, and sort them by liquidation status.
  2. Register a refund bank account in the ACE Portal, if it is not done.
  3. File CAPE declarations for the entries CAPE accepts today, through your broker or yourself.
  4. For finally liquidated entries, ask a trade lawyer whether to wait as a member of the class or to sue on your own: deadlines run, and the choice depends on the amounts at stake.

What TariffTrust does, and does not do

TariffTrust does not file entries or refund claims and gives no legal or eligibility opinion. Its calculations start with its first edition in service, September 28, 2026, after the end of the IEEPA duties: it does not work out what your 2025 entries paid under IEEPA, which your entry summaries and your broker show. It follows the official actions as they come in its trade updates, and calculates the duties in force today.

Updated October 30, 2026. General information as of that date, not legal or customs advice: the official texts prevail, and a licensed customs broker can confirm what applies to your goods.

Calculate your duties

The IEEPA duties have ended; see what your goods owe now, under the duties in force: enter their HTS code, their country of origin and their value. Free, no sign-up.