Your IEEPA Tariff Refund Is Coming — Here’s What CBP Just Told the Court

If you’ve been paying IEEPA duties on your imports over the past year, you already know the Supreme Court ruled those tariffs illegal. The question on every importer’s mind since then has been simple: when do I get my money back?

We got a meaningful update on March 31, when CBP filed its latest declaration with the Court of International Trade. The short version: the refund system is taking shape, but there are details you need to understand now to make sure you’re not left waiting longer than you have to.

The System CBP Is Building

CBP is building a new module inside ACE called CAPE — Consolidated Administration and Processing of Entries. It has four parts: a claims portal where importers or their brokers submit declarations, a mass processing engine, a review and liquidation component, and a refund mechanism.

As of March 30, the claims portal is about 85% done. The mass processing engine sits at 60%. Review and liquidation is at 80%, and the refund component is at 75%. CBP has not given a firm go-live date, but earlier filings pointed to late April.

What Phase 1 Will Cover

Phase 1 won’t cover every entry. CBP estimates it will handle roughly 63% of entries on which IEEPA duties were paid or deposited. That includes unliquidated entries and entries still within the 90-day voluntary reliquidation window.

Entries with suspended, extended, or under-review liquidation status will be accepted too. CBP will strip the IEEPA HTS codes and recalculate duties, but won’t actually process the refund on those until they liquidate in the normal course. Same goes for warehouse entries.

What’s excluded from Phase 1: entries flagged for reconciliation, entries on a drawback claim, entries covered by an open protest, entries not filed in ACE, and certain AD/CVD entries pending Commerce Department liquidation instructions.

What You Should Do Right Now

First, if you haven’t signed up for electronic refunds with CBP, do it. As of late March, about 26,664 importers of record have completed that process, covering roughly $120 billion in IEEPA duties. CBP has required electronic disbursement since February, so if you’re not set up, you’re holding up your own refund.

Second, once CAPE goes live, CBP says it will take up to 45 days from acceptance of your declaration to review and process it. That clock doesn’t start until you file.

The importers who recover the most money the fastest will be the ones who know exactly which of their entries qualify for Phase 1, which ones fall into later phases, and how to file clean declarations the moment the portal opens. That’s the kind of entry-level analysis we do for our clients. If you want help figuring out what you’re owed and making sure nothing falls through the cracks, get in touch — we work on a success-fee basis, so you don’t pay unless you recover.