How to Claim Your IEEPA Tariff Refund Through the CBP CAPE Portal (2026 Guide)

Background: Why Importers Are Owed Refunds

The Court of International Trade (CIT) ruled that President Trump's use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs exceeded executive authority. The ruling mandated that Customs and Border Protection (CBP) refund all IEEPA duties collected — an estimated $166 billion across tens of thousands of importers.

IEEPA duties covered imports from most trading partners, including China, Canada, Mexico, Brazil, India, and others. Critically, these are distinct from Section 301 tariffs (China-specific, still in effect) and Section 232 duties on steel and aluminum (also still in effect). To determine your refund exposure, your customs broker can pull your entry data and flag which entries were assessed under IEEPA authority.

The government did not file a Federal Circuit appeal by the approximately March 20, 2026 deadline — a significant development. The refund obligation is now legally firm. CBP is building the CAPE (Customs Automated Processing Engine) portal specifically to handle the volume of refund claims at scale.

Want to estimate what you might recover? Use our IEEPA refund calculator to get a quick estimate based on your import volume and commodity categories.

Two Pathways to Your Refund: Phase 1 vs. Phase 2

Not all importers follow the same route. CBP has structured the refund process in phases, and your pathway depends on the liquidation status of your entries:

Phase 1 Step-by-Step: ACH Electronic Refund

Phase 1 covers approximately 63% of all IEEPA entries — those that are unliquidated or within the 90-day voluntary reliquidation window. As of March 26, 2026, 26,664 importers have enrolled for electronic refunds. If you are already enrolled, here is what to do:

Step 1: Verify ACH/EFT Enrollment in ACE

Phase 1 refunds are electronic-only. Paper checks have been permanently discontinued. Log into the ACE (Automated Commercial Environment) portal and confirm your ACH/EFT payment details are current and active. If you are not enrolled, your customs broker can initiate enrollment — but do this immediately, as processing takes time.

For a detailed walkthrough of the ACH enrollment process, see our ACE ACH setup guide for IEEPA refunds.

Step 2: Compile Your IEEPA Entry Data

Work with your customs broker to pull a complete list of entries assessed under IEEPA authority. Key data points to collect:

• Entry numbers and entry dates
• Country of origin for each entry
• IEEPA duty amounts paid (broken out from Section 301 or 232)
• Liquidation status of each entry
• Importer of Record (IOR) number

Brazil and India IEEPA duties are explicitly in scope of the refund order. If you import from either country, ensure those entries are included in your compilation.

Step 3: Submit a CAPE Declaration After April 20

When the CAPE portal opens on approximately April 20, 2026, importers will submit a CAPE Declaration — a structured electronic submission confirming your IEEPA entry data. You do not need to submit anything before the portal opens. CBP will process declarations and initiate reliquidation, triggering automatic ACH payments to your enrolled bank account.

CBP's build status as of March 31, 2026: Claim Portal (~85% complete), Mass Processing (~60%), Review & Reliquidation (~80%), Refund (~75%). All components are progressing toward the April 20 target.

Step 4: Monitor the April 14 Court Status Report

The next significant court event is April 14, 2026. CBP must file a status report at noon EDT, followed by a closed conference with Judge Eaton at 3:00 PM EDT. This conference will likely produce updated guidance on Phase 1 readiness and Phase 2 implementation — watch for the court order that follows.

Phase 2 Step-by-Step: Protest Pathway for Finally Liquidated Entries

If your entries are finally liquidated — meaning they have gone through the formal CBP liquidation process and the protest window appeared to have closed — you still have a pathway to a refund. On March 27, 2026, Judge Eaton issued an expanded order requiring reliquidation of finally liquidated entries. These will be processed under Phase 2 of CAPE, with a timeline yet to be determined.

Step 1: Determine If Your Entries Are Finally Liquidated

An entry is "finally liquidated" when CBP has completed the liquidation process and the statutory protest period (180 days) has passed without a timely protest being filed. Your customs broker can check liquidation status through the ACE portal. If your entries are not yet finally liquidated, you may qualify for Phase 1 — confirm the status before taking further action.

Step 2: File a Protest Under 19 U.S.C. § 1514

For finally liquidated entries, the appropriate mechanism is a protest under 19 U.S.C. § 1514. The March 27 order specifically authorizes CBP to reliquidate these entries, but filing a protest creates an additional legal record and preserves your rights in the event of future scope litigation. Your customs broker or a trade attorney can prepare and file the protest.

For a detailed walkthrough of the protest process, see our guide to filing a CBP protest for IEEPA refunds.

Step 3: Await Phase 2 CAPE Portal Processing

Phase 2 will handle finally liquidated entries through the CAPE system. The timeline is not yet published — it will be addressed in upcoming court status conferences including the April 14 session. Stay in contact with your customs broker to monitor for Phase 2 guidance and ensure your entry data is ready when the portal opens for these claims.

Which Countries and Duties Are in Scope?

The refund order covers duties imposed under IEEPA authority. This includes tariffs on imports from China (the IEEPA fentanyl and Liberation Day tariff components), Canada, Mexico, Brazil, India, and most other trading partners. Key points:

• In scope: IEEPA-based duties, including Brazil and India tariff rates
• Not in scope: Section 301 tariffs on China (separate statutory authority, not struck down)
• Not in scope: Section 232 steel and aluminum tariffs (separate statutory authority)
• Not in scope: Normal MFN (most-favored nation) rates under the Harmonized Tariff Schedule

Not sure if your entries qualify? Use our eligibility screener to quickly assess your IEEPA refund eligibility based on commodity, country, and entry date.

Common Mistakes to Avoid

Waiting for a paper check

Paper checks have been permanently discontinued. If you are not enrolled in ACH/EFT in the ACE system, CBP has no mechanism to pay you electronically. Do not wait — enroll now.

Confusing IEEPA duties with Section 301 duties

Section 301 tariffs on Chinese imports remain in effect — they were not struck down and are not subject to this refund process. Make sure your customs broker isolates IEEPA duty amounts specifically when computing your refund entitlement.

Assuming finally liquidated entries are not eligible

The March 27, 2026 order specifically brings finally liquidated entries into scope. If you previously believed your entries were ineligible because they were finally liquidated, reconsider — and consult your customs broker about filing a protest to preserve your claim.

Submitting anything before the CAPE portal opens

There is nothing to submit before approximately April 20, 2026. The portal is not yet live. Any third party asking you to pay a fee or file a document with CBP before portal launch should be approached with skepticism. The process is free to importers and handled through official CBP channels.

Key Dates at a Glance

Your Action Checklist Right Now

1. Confirm ACH/EFT enrollment — Check your ACE account and ensure electronic payment details are active and current.
2. Identify your IEEPA entries — Work with your customs broker to separate IEEPA duties from Section 301/232 duties across all entries.
3. Check liquidation status — Determine whether each entry is unliquidated (Phase 1) or finally liquidated (Phase 2 protest pathway).
4. File protests if needed — If any of your entries are finally liquidated, file a 19 U.S.C. § 1514 protest to preserve your legal position.
5. Monitor April 14 — The court status conference will produce updated CBP guidance. Watch for the order that follows.
6. Submit CAPE Declaration after April 20 — Do not submit anything before the portal opens. When it does, file promptly.

Frequently Asked Questions