If you imported goods and paid IEEPA tariffs, you may be owed money back. After the Supreme Court struck those tariffs down in 2026, CBP opened a refund process called CAPE inside the ACE Portal. The importer of record, or their customs broker, files the claim. Section 232 and Section 301 duties are not part of it and still apply.
What actually changed For most of the last two years, a wide band of imports carried an extra tariff that traced back to the International Emergency Economic Powers Act, or IEEPA. The President used that law to set those duties. In 2026 the Supreme Court ruled the law does not give the President that power, so the IEEPA tariffs were unlawful.
That ruling did two things for brands that import. It stopped the IEEPA tariff going forward, and it opened the door to refunds on what you already paid. CBP built a dedicated process for the second part, because refunding millions of past entries one at a time would take years.
The process is called CAPE, short for Consolidated Administration and Processing of Entries. It lives in the ACE Portal, the same system your customs broker already uses to file entries. If you have ever paid duty on an ocean or air shipment into the US, your entry data is already in there.
One caution before you plan around this. The IEEPA refund is real and it is happening now, but the wider tariff picture is still moving. The government has other tariff authorities it can reach for, and trade policy can shift again. So treat the IEEPA refund as money you are owed for duties already collected, not as a sign that your landed costs are about to drop for good. Recover what you overpaid, then keep planning your sourcing as if tariffs are a permanent line item, because for most categories they still are.
What's refundable, and what isn't This is where a lot of operators get the wrong number in their head, so read this part twice.
Only IEEPA tariffs are refundable. Those are the duties the court actually struck down. On your entry paperwork they show up under HTS lines that start with 9903.01 or 9903.02. Those codes are the marker you are looking for.
Everything else stays exactly where it was. Section 232 duties on steel and aluminum are still in effect and are not refundable. Section 301 duties, including the China lists most brands know well, are still in effect and are not refundable. Standard most-favored-nation duty, the base rate on the product itself, was never in question.
So if you import from China and paid a stack of duties, only the IEEPA slice comes back. The Section 301 portion does not. Map your entries before you get attached to a total, or you will quote yourself a refund that is two or three times what CBP will actually send.
Who can file the claim The claim belongs to the importer of record. That is whoever was listed as the IOR when the goods cleared customs and whoever paid the duty. For most brands that is your own company, filing under your EIN.
You do not have to file it yourself. The customs broker who filed your original entries can file the CAPE claim for you, and most will. If a broker handled your imports, start there. They already hold your entry numbers and they file in ACE every day.
What you cannot do is claim a refund on duty you did not pay. If your supplier imported the goods as the IOR and you bought them landed, the refund follows the IOR, not you. Check who was actually on the entry.
How CAPE works, step by step The Phase 1 process is built to be fast and light. You are not submitting a pile of evidence up front. You are handing CBP a list of entry numbers and letting their system match it against what you paid.
Get your ACE Portal account in order. You need an account with the Importer sub-account active. This is also where you add the bank details CBP will pay the refund into, so confirm the ACH information is current before you file.Pull your entry list. Run the Entry Summary report in ACE. It shows every entry number and HTS line. Filter for lines starting with 9903.01 or 9903.02 to isolate the IEEPA entries that qualify.Check eligibility on timing. Phase 1 covers entries that have not yet liquidated, plus entries that liquidated within 80 days of the date you submit. Liquidation is the point where CBP finalizes the duty on an entry. Older liquidated entries fall to later phases or other channels, so flag them and move on.File the CAPE Declaration. You upload a CSV of the qualifying entry numbers into the CAPE tab in ACE. That CSV is the declaration. Phase 1 asks for the entry list, not supporting documents, so the filing itself is quick once your list is clean.Let CBP validate. Their system checks the file, then validates the individual entries against what was paid. Claims that pass validation move into the refund queue.Your broker can run all five of these for you. If you self-file, the work sits mostly in steps one and two: a clean account and an accurate entry list do most of the job.
What about older entries that already liquidated? Phase 1 has a hard edge on timing. It only reaches entries that are still unliquidated or that liquidated within 80 days of your submission. A lot of brands have IEEPA duty sitting on entries that liquidated well before that window. Those do not disappear, but they do not flow through Phase 1 either.
For older liquidated entries, the traditional route is a protest. You generally have 180 days from the date of liquidation to file a protest with CBP contesting the duty. That is a separate filing from CAPE, and it is the kind of work most brands hand to a customs broker or a trade attorney rather than run themselves. CBP has signaled that later phases of CAPE will widen the entry window, so part of the job right now is simply knowing which bucket each of your entries falls into.
The practical move: sort your IEEPA entries by liquidation date. Recent and unliquidated entries go through CAPE now. Older liquidated entries get a protest decision, ideally before the 180-day clock runs out. Do not let an eligible entry age out while you wait for a later phase that may arrive too late for it.
What you'll get back, and when Valid claims are generally paid within 60 to 90 days of CBP accepting the declaration, unless something on the entry triggers a closer review. The refund includes interest on the duty you overpaid, which CBP calculates for you. You do not need to compute the interest yourself.
The money lands in the ACH account tied to your ACE profile, which is why getting the bank details right in step one matters more than it looks. A wrong or missing account is the most common reason a clean claim stalls.
Treat the number as an estimate until it clears. CBP validates entry by entry, and an entry that was amended, protested, or already partially refunded can come back lower than your spreadsheet says. The 9903 lines tell you what is in scope. CBP's validation tells you what actually pays.
A few things stall otherwise valid claims, and all of them are avoidable. Stale or missing ACH bank details on your ACE profile are the most common, so fix that first. Entry numbers typed or exported wrong in the CSV will fail file validation, which is why pulling them straight from the Entry Summary report beats rekeying them by hand. And entries that mix IEEPA duty with a separate compliance flag can get pulled for manual review, which adds weeks. None of these are reasons not to file. They are reasons to file from clean data.
What to do this week You do not need a lawyer to start. You need your records in order and a decision on who files. A short checklist:
Confirm whether you, or your supplier, were the importer of record on your 2025 entries. The refund follows the IOR. Ask your customs broker if they are filing CAPE claims on your behalf. If yes, give them the green light and your entry range. If no, you file in ACE. Log into ACE, confirm the Importer sub-account is active, and check that your ACH bank details are current. Pull the Entry Summary report and filter for 9903.01 and 9903.02 lines so you know your real IEEPA exposure before anyone quotes you a total. Keep Section 232 and 301 duties out of your refund math. They are not coming back. Where fulfillment fits in A third-party logistics provider is not your customs broker, and a refund claim is a customs filing. So the honest framing is this: your 3PL does not file your CAPE claim. Your broker or your own team does.
What your 3PL does touch is the record trail underneath the claim. Clean inbound receiving and an accurate match between what you ordered and what arrived make the entry reconciliation faster when your broker pulls the list. Messy inbound records are where refund prep slows down.
Get your inbound records right Refunds reward the brands whose paperwork already lines up. The same accurate inbound data that makes a refund claim painless keeps your fulfillment honest the rest of the year.
Simpl Fulfillment ships for growing brands and keeps the inbound side clean, so your records are ready when you need them. Pricing starts at $7/order, flat. Talk to us if you want a fulfillment partner that keeps the receiving paper trail tight.
