If you imported goods and paid IEEPA tariffs, you may be owed money back. The Supreme Court ruled against those tariffs in Learning Resources, Inc. v. Trump on February 20, 2026, and CBP now takes refund requests through a process called CAPE inside the ACE Portal. The importer of record, or the customs broker that filed its entries, submits the request. Section 232 and Section 301 duties are not part of it and still apply.
What actually changed
In 2025, a wide band of imports carried extra tariffs that the President set under the International Emergency Economic Powers Act, or IEEPA. The Supreme Court held on February 20, 2026 that IEEPA does not authorize the President to impose tariffs.
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 so it could refund IEEPA duties and interest in consolidated batches instead of entry by entry.
The process is called CAPE, short for Consolidated Administration and Processing of Entries. It lives in the ACE Portal, the system your customs broker already files entries in. CBP launched it on April 20, 2026 and is adding entry types in phases, so the list of what it accepts has already grown and may grow again.
One caution before you plan around this. The IEEPA refund 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.
What's refundable, and what isn't
This is where a lot of operators get the wrong number in their head.
Only IEEPA duties come back through CAPE. On your entry summary they sit on HTS Chapter 99 lines, and CBP's test is that each entry declared at least one dutiable IEEPA HTS Chapter 99 code. Don't try to spot them by a code prefix. ACE's ES-003 Entry Summary Line Tariff Details report, run with the IEEPA tariff indicator, shows the entry lines that may qualify.
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 far bigger than 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. CBP lets the IOR or the customs broker that filed the entries submit the CAPE Declaration. If a broker handled your imports, start there. They already hold your entry numbers and they file in ACE every day.
Who gets paid is a separate question. CBP pays the refund to the IOR or, if one is designated on the entry, to the CBP Form 4811 notify party the IOR named to receive refunds on its behalf. If your broker or a financing company is your 4811 notify party, the refund goes to them, not to you. You can add the CF 4811 notify party fields to an ACE entry summary report to check. And if your supplier imported the goods as the IOR and you bought them landed, the refund follows the IOR, not you.
How CAPE works, step by step
CAPE is built to be light. You are not submitting a pile of evidence up front. You are handing CBP a list of entry numbers and letting its system match them against what you paid.
- Get your ACE Portal account in order. You need an ACE Portal account with an Importer sub-account. Refund bank details are a separate enrollment from the ACH you use to pay CBP; you add them under the ACH Refund Authorization tab in the Importer sub-account. If CBP has no refund account on file, it holds the refund until you provide one.
- Pull your entry list. Run the ES-003 report with the IEEPA tariff indicator to find entry lines with IEEPA duties. Keep the entry numbers exactly as ACE exports them.
- Check eligibility. CAPE currently takes most entries that are unliquidated or up to 80 days past liquidation, including entries flagged for reconciliation with no reconciliation entry filed yet and warehouse withdrawal entries. Liquidation is the point where CBP finalizes the duty on an entry. The next section covers what CAPE won't take.
- File the CAPE Declaration. Upload a CSV of the qualifying entry numbers in the CAPE tab in ACE. That CSV is the declaration. CBP asks for nothing else in the file, each declaration holds up to 9,999 entries, and once it's filed you can't remove entries or cancel it.
- Let CBP validate. ACE checks the file first (right filer, a list of entry numbers, correct format), then each entry. An entry is rejected if it isn't in ACE, has no dutiable IEEPA Chapter 99 code, or already appeared on a declaration. You can download the results from the CAPE tab and resubmit fixed entries on a new declaration.
Your broker can handle steps two through five. Step one is yours: CBP can only pay a recipient that has its U.S. bank account information in its own ACE Portal account.
What CAPE won't accept yet
CBP lists several kinds of entries as not currently accepted on a CAPE Declaration. Three are the ones a small importer is most likely to hit:
- Entries covered by an open protest. If you already protested an entry, CAPE rejects it.
- Entries on a drawback claim. CBP encourages putting drawback-eligible entries on a CAPE Declaration before you file the drawback claim.
- Entries whose liquidation is final.
The rest of the list: reconciliation summaries (entry type 09), entries flagged for reconciliation with the type 09 already filed, warehouse entries (types 21 and 22), entries not filed in ACE or with no ACE liquidation status, and AD/CVD entries pending liquidation under 19 U.S.C. § 1504(d).
You also can't request an IEEPA refund by filing a Post Summary Correction. CBP prohibits it. If an entry needs a correction that has nothing to do with IEEPA, file that PSC before you put the entry on a CAPE Declaration.
What about older entries that already liquidated?
CAPE has a hard edge on timing. It only takes liquidated entries that liquidated within the preceding 80 days, which leaves CBP time to reliquidate by the 90th day, its legal window for voluntary reliquidation. A lot of brands have IEEPA duty sitting on entries that liquidated before that. CBP says it is evaluating entries with final liquidation for future CAPE deployments but has given no timeline.
For those entries, the traditional route is a protest. You generally have 180 days from the date of liquidation to file one. A protest and CAPE don't mix, though. An entry covered by an open protest is not accepted in CAPE, and once an entry is on a CAPE Declaration you can't file a PSC or a protest on it. CBP's guidance is to wait until the refunds on those entries have been issued, then protest any non-IEEPA issues. That is why the protest decision belongs with a customs broker or trade attorney, entry by entry.
The practical move: sort your IEEPA entries by liquidation status and date. Unliquidated entries and entries liquidated within the last 80 days go on a CAPE Declaration now, before their window closes. For older liquidated entries, decide with your broker or attorney whether a protest makes sense before the 180-day clock runs out, knowing that a protested entry can't then go through CAPE.
What you'll get back, and when
CBP says valid IEEPA refunds are generally issued within 60 to 90 days after it accepts the CAPE Declaration, unless a compliance concern needs further review. That window covers about 45 days of CBP processing plus time for the Treasury to certify the money. Entries whose liquidation is suspended, extended, or under review, and warehouse entries, keep that status, and their refund is issued only when they liquidate. Once an entry liquidates or reliquidates, most refunds reach the ACH account in 3 to 5 weeks.
The refund includes interest on the duty you overpaid, which CBP calculates and pays with the refund. You do not need to compute the interest yourself, and there is no separate interest payment.
Treat the number as an estimate until it clears. CBP nets each entry at liquidation: if other duty on the entry changed, from a classification or value correction for example, that difference comes out of the refund, and CBP can apply a refund to any unpaid debt you owe it. Refunds are also batched by recipient and liquidation date, so one declaration can arrive as several deposits. The Chapter 99 codes tell you what is in scope. CBP's validation and liquidation tell you what actually pays.
A few things hold up otherwise valid claims. A missing refund bank account is the big one, and the REV-613 report lists refunds rejected for incomplete ACH refund enrollment. Entry numbers typed or exported wrong fail validation, which is why pulling them straight from ACE beats rekeying them by hand. Suspended or extended entries wait for liquidation, and an entry with a compliance concern gets further CBP review before it pays.
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 IEEPA-era entries, and whether a CBP Form 4811 notify party is listed on them. Refunds go to the IOR or that notify party.
- Ask your customs broker if they are filing CAPE declarations for you. If yes, agree on the entry range. If no, you file in ACE.
- Log into ACE, confirm the Importer sub-account is active, and set up refund bank details under the ACH Refund Authorization tab. The ACH account you pay duties from does not count.
- Run ES-003 with the IEEPA tariff indicator so you know your real IEEPA exposure before anyone quotes you a total.
- Flag entries with an open protest, a drawback claim, or final liquidation. CAPE won't take them yet.
- 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.
Your 3PL's part starts after the goods clear customs: receiving the inventory and shipping your orders. The CAPE claim runs on the entry data your broker filed in ACE, not on warehouse records, so keep the customs work with your broker.
Once your goods clear customs
Simpl Fulfillment receives inbound inventory in 1–3 days and ships your orders from there. Fulfillment is priced starting at $7/order, with a $750/month minimum billed pay-the-difference: if a month's orders bill under $750, you pay only the gap. That's about 100 shipments a month at the lowest weight (0.5 lb or less). See pricing, or read how we work.