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How To Claim Your IEEPA Tariff Refunds: Step-by-step
A guide for getting back what CBP owes you - even if you've never dealt with customs before
Gowtham Ramachandran
April 20, 2026
I came across a startling stat yesterday.
Of the 330,000 importers collectively owed over $166 billion in tariff refunds, only 56,000 have done the basic setup to receive their money.
56,000….
That's ONLY 17%.
The rest either don't have a cash problem big enough to care - or they just don't know how to go about claiming what's theirs.
My best guess is the latter.
So I spent the last few days digging through government guidance, legal filings, and broker walkthroughs to figure out exactly what it takes. And what I found is that the process is actually pretty straightforward. It's just buried under a mountain of customs jargon that makes it feel like it's not for you.
Here's exactly what it takes to file for your IEEPA tariff refund - broken down so anyone can follow it:
What’s Inside
👉️ This one’s free to read.
1. What happened, in plain English
In 2025, the US government imposed a set of emergency tariffs on imports using a law called the International Emergency Economic Powers Act, or IEEPA. If you imported goods during that period, you paid those tariffs.
In February 2026, the Supreme Court ruled those tariffs were illegal. The government collected money it wasn't supposed to collect. Now it has to give it back.
The numbers are staggering. More than 330,000 importers brought in over 53 million shipments subject to these tariffs. The total refund pool is roughly $166 billion.
The agency handling the refunds is US Customs and Border Protection (CBP). They built a new online system called CAPE to process the claims.
That system went live this morning (April 20, 2026).
One important thing to know upfront: this only applies to IEEPA tariffs. Other tariffs, like the Section 301 tariffs on Chinese goods, are not affected by this ruling and are not being refunded. If you're not sure which tariffs you paid, your customs broker can tell you. The ones you're looking for will be labeled IEEPA or listed under HTS Chapter 99 on your entry documents. Chapter 99 is just the section of the tariff schedule where IEEPA duties were recorded - think of it as the label CBP used to track them.
One more thing worth knowing: these refunds are not automatic. CBP has all the information. They know who paid IEEPA duties and how to reach them. But they're not sending checks in the mail. You have to opt in, follow the process, and wait for your claim to be approved. That's exactly what this guide is for.
2. The two systems you need to know about: ACE and CAPE
Before jumping into the steps, it's worth taking sixty seconds to understand the two systems you'll be working with. A lot of the confusion around this process comes from people not knowing how they relate to each other.
ACE - the building
ACE stands for Automated Commercial Environment. It's CBP's main online portal where all US customs filing happens. Importers and customs brokers use it every day to file shipment records, run reports, and manage entries. If you've never used it before, you'll be creating an account as part of this process.
CAPE - the room inside the building
CAPE stands for Consolidated Administration and Processing of Entries. It's a new tool that CBP built specifically to handle IEEPA tariff refund claims. It lives inside ACE as its own tab. You don't sign up for CAPE separately - you access it through your ACE account.
So when you file for your refund, you log into ACE, and then you use the CAPE tab within ACE to submit your claim. Every step in this guide flows through one or both of these systems. Once you understand that relationship, the rest of the process makes a lot more sense.
3. What you'll need before you start
Before jumping into the steps, it's worth taking stock of what you actually need to have on hand. Most people hit a wall midway through this process not because the steps are complicated, but because they're missing data they didn't know they needed.
Here's everything required, and where to find it.
Your company EIN (Employer Identification Number)
This is your federal tax ID - the same number on your tax returns. You'll need it to register for an ACE Portal account. If you don't have it handy, your accountant or finance team will.
Your ACE Portal login
If your company already has an ACE account, find out who owns it and get access. If nobody in your organization knows, that's a signal you've been fully reliant on your customs broker - which is common, but means setting up an account is your first real task. New account registrations can take days to weeks at larger companies due to IT approvals, so start this immediately.
A US bank account and routing number
CBP pays refunds exclusively via electronic bank transfer (ACH). You'll need your bank's 9-digit routing number and your account number to enroll. If you're a non-US importer without a US bank account, you'll need to designate a US party to receive the refund on your behalf - this requires an additional form (CBP Form 4811) filed in advance.
Your entry data
This is the big one, and where most people get stuck.
An "entry" is the record CBP creates every time a shipment crosses the US border. Every entry has a unique 11-character entry number. To file for a refund, you need a list of every entry number on which IEEPA duties were paid - along with the liquidation status of each one (whether CBP has finalized it and when).
Where to get this:
If you have ACE access: You can pull this yourself by running an Entry Summary Report filtered by HTS Chapter 99 - the code CBP used to record IEEPA duties. The report will show every qualifying entry, the duties paid, and the liquidation status.
If you don't have ACE access: Call your customs broker. Ask them specifically for "a list of all entries with IEEPA HTS Chapter 99 duty codes, including liquidation dates and statuses." They have this data. It may take them a day or two to pull and format it, so ask now.
If you used multiple brokers: You'll need to contact each one separately, since brokers can only see the entries they filed. Don't assume one broker has the full picture.
A rough sense of your exposure
You don't need an exact number before you start, but it helps to know whether you're dealing with dozens of entries or thousands. A $10,000 refund and a $10 million refund go through the same process - but the data preparation looks very different. If your broker can give you a rough total of IEEPA duties paid alongside the entry list, use that number to decide how much time and attention this deserves.
One important check: are you the Importer of Record?
The refund goes to whoever was listed as the Importer of Record (IOR) on the original customs entry - the party that legally brought the goods into the US and paid the duties. If that's you, you're in the right place. If a freight forwarder, 3PL, or supplier was listed as the IOR on your entries, the refund flows to them - not you - and you'll need to have a separate conversation about how that money gets passed back.
Not sure who your IOR is? Check ImportYeti - it's a free tool that shows public US import records by company name. If your company name shows up on shipments, you're likely the IOR. If your 3PL or supplier's name shows up instead, you have some digging to do before filing.
What CBP actually checks on your entries
Before you file, it's worth knowing what CBP looks at when they review your entries on the back end. If any of these are inaccurate or inconsistent, your refund can be delayed or flagged for a compliance review:
Country of Origin - where the goods were actually manufactured
HTS Classification - the tariff code assigned to your product
Customs Valuation - the declared value of the goods
Anti-Dumping / Countervailing Duties - whether any additional duties apply
Section 301 / Section 232 Duties - other tariff layers on your entries
Importer of Record Accuracy - whether the correct entity is listed as IOR
Product Description Accuracy - whether goods are described correctly
Related Party Transactions - whether buyer and seller are related entities
PGA Compliance - Partner Government Agency requirements (FDA, USDA, etc.)
If any of these are off, fix them before filing. A rejected or flagged entry doesn't just delay your refund — it can open up broader compliance exposure you don't want.
Once you have all of the above, you're ready to move through the six steps without hitting unexpected walls. If you're missing any of it - particularly the entry data - stop and get it before proceeding. Filing without clean, complete entry data is the fastest way to get your declaration rejected on the back end.
4. Before you start: Know where you stand
Not every entry qualifies right now. CBP is processing refunds in phases, and Phase 1, which is open now, covers two situations:
You qualify for Phase 1 if:
Your shipment entry hasn't been liquidated (finalized) by CBP yet, OR
CBP liquidated it within the last 80 days
You don't qualify for Phase 1 if:
CBP liquidated it more than 80 days ago
If that second point applies to some or all of your shipments, don't panic. Phase 2 is coming, likely sometime in summer 2026, and it will cover those older entries. Complete Steps 1 and 2 now anyway, because you'll need them when Phase 2 opens.
Here's why timing matters: entries are aging out of Phase 1 eligibility every single day. The longer you wait, the more of your shipments cross that 80-day threshold and fall into the slower Phase 2 process.
A quick note on liquidation, since it came up in section 3: when your shipment arrives, you pay an estimated tariff bill. CBP then reviews it and determines the final amount — usually within 314 days. Once that's settled, the entry is considered liquidated. After liquidation, you have a 180-day window to flag any disputes. Phase 1 covers entries that haven't reached that final stage yet, or reached it within the last 80 days.
A note on the numbers: depending on how you measure it, Phase 1 covers somewhere between 63% and 82% of total IEEPA duties paid. CBP quotes 63% of entries; others measure it as 82% of total duty value. Either way, the majority of what's owed can be claimed right now.
5. Step 1: Set up your ACE Portal account
What you're doing: Registering on CBP's filing system so you can access the CAPE tab and submit your refund claim.
Why it matters: Everything happens inside ACE - submitting your claim, entering your bank details, tracking your refund. No account, no refund.
How to do it:
Go to ace.cbp.dhs.gov. Register for an account using Form 5106. If you already have an account, skip straight to checking that you have an Importer sub-account - that's the specific account type that unlocks the CAPE tab and ACH refund enrollment. Without it, you can't file.
What you'll need:
Your company's legal name
Your EIN (federal tax ID number - the same one on your tax returns)
The name of the person who will manage the account
One thing to clarify upfront: attorneys cannot file CAPE declarations on your behalf. Only the Importer of Record, or the specific customs broker who filed the original entry, can submit a claim. More on this in Step 4.
6. Step 2: Add your bank account for the refund
What you're doing: Enrolling your bank account so CBP knows where to send your money.
Why it matters: As of February 2026, CBP no longer sends paper checks. Every refund goes out electronically, straight to a bank account. If your bank details aren't on file, CBP will hold your refund until they are. The money just sits there.
How to do it:
Log into your ACE Portal account and navigate to your Importer sub-account. Look for the tab labeled ACH Refund Authorization. ACH just means electronic bank transfer - it's the same system used for direct deposit payroll. That's where you enter your bank information.
You'll need:
Your bank's routing number (9 digits, found on any check)
Your account number
Account type (checking or savings)
Critical detail: If you've previously set up ACH for paying duties outbound, that is a completely separate setup from the refund enrollment. You need to do both. Having one does not mean you have the other.
If you're a non-US importer: CBP requires a US-based bank account to receive refunds. If you don't have one, you can designate a US party to receive the refund on your behalf using CBP Form 4811.
One more thing: if you have any outstanding debts to CBP, they will deduct those from your refund before paying you the remainder. This won't disqualify you from filing, but it's worth knowing before you build a cash flow forecast around the full refund amount.
7. Step 3: Find out which shipments are eligible
This is where I'd recommend pulling in your customs broker if you have one. The report itself is straightforward, but having someone who knows your entry history makes this a lot faster.
What you're doing: Running a report inside ACE to identify every shipment on which you paid IEEPA tariffs.
Why it matters: You can't file for a refund on a shipment you can't identify. This step is about building your list.
How to do it:
Inside ACE, go to the Reports section and run an Entry Summary Report. Filter it by:
Date range: January 2025 through today
HTS Chapter 99 (this is the label CBP used to record IEEPA duties - you can cross-reference the HTS schedule here)
The report will show you every shipment that had IEEPA duties attached to it, the status of each one, and the date it was liquidated if applicable.
Sort your results into three buckets:
Not yet liquidated by CBP - highest priority, file immediately
Liquidated within the last 80 days - file before they age out of Phase 1
Liquidated more than 80 days ago - flag these for Phase 2, and talk to a trade attorney if the amounts are large
If you're not sure how to run this report, your customs broker can pull it for you. Ask them specifically for a list of entries with IEEPA Chapter 99 duty codes and their liquidation statuses. If you want to check whether your company appears as an importer of record in public shipping records, ImportYeti is a useful free tool.
8. Step 4: Build your filing list
Honestly, this was the step I expected to be complicated. It isn't.
What you're doing: Creating a simple spreadsheet of entry numbers to upload into CAPE.
Why it matters: This spreadsheet is called a CAPE Declaration. It's your actual refund claim. When you upload it, CAPE strips out the IEEPA duty charges from each entry, recalculates what you owe without them, and issues you the difference.
How to do it:
Inside ACE, find the CAPE tab and download the CAPE Upload Template. It's a simple Excel file with one column: Entry Number. No amounts, no dates, no additional information needed. CBP has also published a CAPE Quick Reference Guide that walks through the filing mechanics.
Fill in your Phase 1 eligible entry numbers, one per row, starting in row 2. Each entry number is 11 characters long, letters and numbers only, no spaces or dashes.
Save the file as a .CSV before uploading. Not .xlsx - you have to convert it first. In Excel, go to File, Save As, and choose CSV from the format options.
A few rules before you submit:
You can include up to 9,999 entries per file. If you have more, split them across multiple files.
Once CAPE accepts your file, you cannot edit it. If you missed entries, submit a second file. An entry can only appear on one accepted filing - if it shows up on two, the second one gets rejected.
Only the Importer of Record can file, or the specific customs broker who filed the original entry on your behalf. Not just any broker, and not your trade attorney. It has to be the broker who actually filed the entry with CBP at the time of import.
Before you submit, check:
Every entry number is 11 characters with no typos
Every entry on your list actually has IEEPA Chapter 99 duty codes
You're not including entries liquidated more than 80 days ago
One last thing on data quality: the Flexport president Sande Manners put it plainly - "the big message is that you have to clean up your act before you ask for a refund." If your entries have errors - wrong tariff codes, inaccurate declared values, paperwork issues - those problems don't disappear when you file for a refund. CBP will flag them on the back end and your refund timeline gets extended. Get your entry data clean before you submit.
9. Step 5: Submit your CAPE Declaration
What you're doing: Uploading your entry list into CAPE and officially requesting your refund.
How to do it:
Log into ACE, go to the CAPE tab, and upload your .CSV file. CAPE runs two rounds of checks:
Round 1 checks that your file is formatted correctly: right column header, right file type, entry numbers are the right length.
Round 2 checks each entry number individually, confirming it exists, that it has IEEPA duties on it, and that it's eligible for Phase 1.
Entries that pass both rounds get accepted. You'll receive a CAPE claim number — a reference ID that tracks your filing. Save it, because you'll need it to monitor your refund in the next step.
Entries that fail will show an error code explaining why. Common reasons:
Entry number has a typo
Entry doesn't have IEEPA duties on it
Entry is already outside the 80-day window
Entry was already submitted on a previous accepted filing
Rejected entries can be fixed and resubmitted on a new filing.
A note on timing: experts warned before launch that a crush of filings on day one could slow the system down. If you run into delays or the system is sluggish, be patient and try again. The portal is open and processing claims - it just may be busy.
10. Step 6: Track your refund
The waiting was the part I found hardest to get clear information on. Here's what I was able to confirm.
How long it takes: CBP estimates 60 to 90 days from when CAPE accepts your filing to when the money hits your account. That timeline can extend if CBP flags anything for a compliance review. Clean declarations with no errors may pay out faster.
How to track it:
Inside ACE, go to Reports and run the REV-615 CAPE Refunds Trade Report. Enter your CAPE claim number. You'll be able to see the status of your entries and, eventually, the refund amount and scheduled deposit date.
What the refund looks like: CBP consolidates everything into a single lump sum deposit via ACH to the bank account you enrolled in Step 2. The refund includes interest on top of the original duty amount, calculated automatically by CBP.
One caveat: if CBP determines you have outstanding debts to the US government, those will be deducted from your refund before the remainder is sent to your account. This is governed by 19 C.F.R. § 24.72.
11. What about shipments that don't qualify for Phase 1?
If some of your entries were liquidated more than 80 days ago, they fall into Phase 2. That phase hasn't launched yet, likely sometime in summer 2026, and will cover those older, fully closed entries.
Two things to do in the meantime:
Talk to a trade attorney if the amounts are large. There's a 180-day window from the date CBP liquidated an entry during which you can file a formal protest to preserve your claim. Some entries may already be approaching that window, so don't sit on it. The American Association of Exporters and Importers (AAEI) and the National Customs Brokers and Forwarders Association of America (NCBFAA) both maintain directories of licensed brokers and trade attorneys if you need a referral.
Complete Steps 1 and 2 now regardless. When Phase 2 opens, you want to be ready to move immediately.
12. One thing to sort out when the money arrives
When the refund hits your account, one question worth thinking through: did you pass any of those tariff costs on to your customers through higher prices?
If you did, there's no automatic mechanism requiring you to pass the refund back downstream. The money goes to whoever was the Importer of Record. But depending on your customer agreements, there may be conversations to have. Better to think it through now than scramble when the deposit lands.
And if the 60 to 90 day wait doesn't work for your cash flow, there is an alternative: some financial firms and logistics companies, including Flexport, are purchasing tariff refund claims outright. You'd get cash now in exchange for handing over the claim and the administrative process. You'll likely get less than the full refund amount, but if you need liquidity immediately, it's worth knowing the option exists.
13. What if you need help or have questions?
CBP has set up two dedicated email addresses for importers navigating this process:
Technical questions about the filing process: [email protected]
General questions about IEEPA refunds: [email protected]
CBP has also published training guides and a walkthrough video on their IEEPA refund page at cbp.gov. If you're setting up an ACE account for the first time or enrolling in ACH refunds, those resources walk you through it step by step.
Finally, I've also interviewed several people on The Conveyor who work in this space and may be able to help with your specific situation:
Adam Dambrov, Founder of AMD Trade Consulting - 30 years in customs and trade compliance, duty drawback, tariff classification, and IEEPA refund filings
Justin Sherlock, licensed customs broker and Co-Founder of Caspian - practical guidance on customs filings and broker operations
Thomas Taggart, VP of Global Trade at Passport - cross-border ecommerce, international shipping, and trade compliance for consumer brands
Parker Burr, Founder of Evana - duty drawback and refund claims, especially for ecommerce brands
Hugo Pakula, CEO of Tru Identity - former trade policy advisor to Congress, expert on tariff law and the SCOTUS ruling
The bottom line
Here's what you need to do, in order:
Gather your data first - EIN, ACE login, bank details, entry list from your broker
Set up your ACE Portal account with an Importer sub-account
Enroll your US bank account for ACH refunds
Pull a report of your IEEPA-eligible entries inside ACE
Build your entry list as a CSV
Upload it into CAPE and submit your declaration
Track your refund using the REV-615 report in ACE
The portal is open. The money is there. Go file for it.
This article reflects CBP guidance as of April 20, 2026. The refund process is subject to ongoing litigation. The government has until early May 2026 to appeal the current court order. Consult a licensed customs broker or trade attorney for guidance specific to your situation.
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