IEEPA Tariff Refunds 2026: How Importers File Claims Through CBP’s CAPE Portal

The question on every importer’s mind for the past two months has finally been answered: yes, IEEPA tariff refunds are happening — and the process is now live.

On April 20, 2026, U.S. Customs and Border Protection opened the CAPE portal (Consolidated Administration and Processing of Entries) inside its Automated Commercial Environment (ACE). It’s the system importers will use to claim back duties paid under the International Emergency Economic Powers Act before the Supreme Court invalidated them in February.

CBP estimates roughly $166 billion in refunds across more than 330,000 importers. If your business paid IEEPA tariffs at any point between their rollout and February 24, 2026, you may be eligible — but refunds are not automatic, and the window for Phase 1 is narrower than many importers realize.

Here’s what changed, how the process works, and what to do this week.

Quick Recap: Why Refunds Are Happening

In February 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA does not authorize the President to impose sweeping tariffs. The ruling invalidated duties on imports from Canada, Mexico, China, and dozens of other countries — including rates as high as 145% on some Chinese goods.

CBP stopped collecting IEEPA tariffs on February 24, 2026. Everything paid before that date is now potentially refundable, depending on how and when it was processed through customs.

How the Refund Process Works Now

CBP’s CAPE portal consolidates refunds across entries instead of processing them one-by-one, which is how duty refunds have historically worked. This is a faster, more scalable path — but it comes with Phase 1 limits that importers need to understand before they file.

Who Can File

Only the importer of record (IOR) can submit a CAPE claim. If your customs broker filed entries under their own IOR number, they’re the party that has to initiate the refund. If you’re the IOR, you or your broker can file on your behalf through ACE.

What Phase 1 Covers

Phase 1 is limited to two categories of entries:

Unliquidated entries — tariffs that were assessed but have not yet been finalized by CBP.

Recently liquidated entries — entries finalized by CBP within the past 80 days.

If your entries were liquidated more than 80 days ago, CAPE Phase 1 will not process them — but you may still have a path through the traditional protest procedure (see below).

How to File

Submissions go through the ACE portal. Importers or brokers provide bank account details for repayment and a declaration listing the entries that paid IEEPA duties. CBP then recalculates the duties without IEEPA and reliquidates the entries, which triggers the refund.

How Long Refunds Take

CBP has said valid claims will generally be paid within 60 to 90 days after acceptance. More complex cases — especially entries flagged for additional review — could take longer. Interest accrual on paid duties is part of the refund, though the mechanics of how interest is calculated are still being clarified.

CAPE or Protest: Which Path Fits Your Entries?

For entries that were liquidated more than 80 days ago but fewer than 180 days ago, importers still have the option to file a formal protest with CBP. This has been the traditional route for disputing assessed duties.

The critical rule: you cannot run both tracks on the same entry. Entries with an open protest cannot be processed through CAPE, and vice versa. If you’ve already filed a protest on IEEPA entries, you’ll need to decide whether to let that protest play out or withdraw it to route the entry through CAPE instead.

Most importers with recent entries will find CAPE faster and simpler. Importers with older entries or more complex situations may be better served by a protest — a conversation to have with your customs broker or trade counsel.

Pending Legislation: The Tariff Refund Act of 2026

Separate from the CBP process, several lawmakers have introduced proposals that would codify refund requirements and add interest or priority treatment for small businesses. The most prominent is the Tariff Refund Act of 2026, which would require full repayment with interest and prioritize small and mid-sized importers.

These proposals are not law yet. The CAPE process is happening regardless, driven by the court ruling and CBP’s own authority, so importers don’t need to wait on Congress to start filing.

A Quick Word on Claim-Buying Firms

With $166 billion in refunds on the table, a secondary market has already appeared. Financial firms are approaching importers with offers to buy refund claims at a discount — cash up front today (for example, $50,000 now for a $100,000 refund later), with the buyer assuming the timing and approval risk.

These offers can make sense for businesses with tight cash flow or uncertainty about whether their entries qualify. They generally don’t make sense for importers whose entries clearly fall into Phase 1, because the 60–90 day CBP timeline is relatively quick and the discount is real money. Run the math before signing anything.

What Importers Should Do This Week

Pull your IEEPA payment history. Work with your customs broker to identify every entry that paid IEEPA duties between the rollout and February 24, 2026.

Sort entries by liquidation status. Separate unliquidated entries, entries liquidated within the past 80 days (Phase 1 eligible), and entries liquidated between 80–180 days ago (protest-eligible).

Confirm who the importer of record is. Only the IOR can file, so if your broker is the IOR, coordinate with them directly.

Get bank account details ready. Refunds are deposited directly, so having ACH information on hand speeds up the filing.

Decide on outstanding protests. If you’ve filed a protest on IEEPA entries, decide whether to continue that path or withdraw and re-route through CAPE.

Don’t book refund dollars into forward cash flow yet. CBP’s 60–90 day estimate is a guideline, not a guarantee. Plan operations conservatively until the money actually arrives.

How 3PL Center Helps Brands Navigate Shifting Tariff Policy

Refund filings are only one part of adapting to the IEEPA unwind. The broader challenge is rebuilding inventory, sourcing, and fulfillment strategies around a changed cost structure — one that no longer carries IEEPA duty but is still evolving as new trade policy moves through Congress.

At 3PL Center, we help brands:

Adjust inventory strategies as landed costs shift

Coordinate container timing and warehouse intake against new duty rates

Distribute inventory across multiple locations to reduce transit exposure

Offset rising costs with discounted carrier rates

Maintain real-time visibility into inventory and order flow

If you’re evaluating how tariff changes or refund cash flow should reshape your fulfillment setup, book a call with our team to walk through your current operation.

Final Takeaway

Two months ago, the question was whether IEEPA refunds would happen at all. Today, the question is whether your business is set up to file correctly in Phase 1.

The CAPE portal is live. The 60–90 day clock starts when your claim is accepted. Importers of record who organize their paperwork this week will be at the front of the $166 billion queue — everyone else will be waiting behind them.