IEEPA Tariff Refunds

The Supreme Court struck down the IEEPA tariffs. You're owed the duty you paid.

On February 20, 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA never authorized tariffs. Every dollar collected under those Chapter 99 lines can come back to the importer of record. CBP pays it through CAPE, a refund function inside ACE, and it pays only on declarations someone files. Caspian finds every eligible entry and files the claim.

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The details

What Is an IEEPA Tariff Refund?

From early 2025 until February 2026, CBP collected IEEPA duties on top of regular duty, reported under HTSUS Chapter 99 headings such as 9903.01.20, 9903.01.24, and 9903.01.33. The ruling left those duties with no legal basis. CBP built CAPE (Consolidated Administration and Processing of Entries) to refund them, and it opens in phases that each cover a different set of entries. An accepted CAPE declaration removes the IEEPA line, reliquidates the entry, and sends the refund by ACH. Entries CAPE can't reach yet still have a path: a protest filed within 180 days of liquidation.

CHAPTER 99 IEEPA

ENTRY SUMMARY IEEPA PAID

HTS8471.30.0100

CH. 999903.01.24

IEEPA$2,458.00

ORIGINCN

CAPE RELIQUIDATION

Know the line items

Which Duties Come Back

Refundable: IEEPA Chapter 99 Duties

Duties whose only legal basis was IEEPA: the baseline reciprocal tariff, the country-specific rates, and the fentanyl-related tariffs. They sit on your entry summaries as 9903.01.xx lines. Caspian isolates every one of them across your ACE history.

Not Refundable: Section 301, 232, 201, 122

Section 301 duties on Chinese goods, Section 232 duties on steel, aluminum, and autos, Section 201 safeguards, and the Section 122 surcharge that took effect February 24, 2026 all stay in force. On a stacked entry only the IEEPA line comes back, so Caspian separates the two line by line and your claim is exact.

The ACH Refund Enrollment Trap

CBP pays IEEPA refunds by ACH, and refund enrollment is separate from the ACH account you use to pay duties. With no refund account on file in ACE, CBP holds the money. Caspian checks your enrollment before the first declaration goes in.

The Process

How Caspian Recovers Your IEEPA Duties

Connect

Caspian pulls your entry summary data straight from ACE and tags every IEEPA Chapter 99 line, with the duty paid and the liquidation status of each entry.

Sort

Each entry goes to the path that still works for it: the open CAPE phase, a protest before its 180-day window closes, or a hold for the phase that covers it next. Every deadline is tracked entry by entry.

File

Licensed customs brokers on our team build and file your CAPE declarations and protests. Entries CBP rejects get corrected and resubmitted.

Collect

CBP removes the IEEPA line, reliquidates the entry, and pays by ACH, generally within 60 to 90 days of acceptance. Caspian tracks each refund until it lands in your account.

Which Do You Need?

CAPE vs. Protests

Most IEEPA refunds go through CAPE. Protests cover the entries CAPE can't reach yet, and they keep the claim alive while CBP opens later phases. Caspian watches every entry's liquidation date and files whichever one the entry needs.

PROTEST

A protest on CBP Form 19 preserves the refund on entries that liquidated more than 80 days before filing and fall outside the open CAPE phases. It has to be filed within 180 days of liquidation. Miss that window and the refund is gone.

CAPE

A CAPE declaration is filed in ACE and covers unliquidated entries and entries within 80 days of liquidation, with later phases reaching further back. It is the faster path. CBP targets payment within 60 to 90 days of acceptance.

Frequently Asked Questions

Who is eligible for an IEEPA tariff refund?

Any importer of record who paid IEEPA duties between February 2025 and February 20, 2026. Industry and company size don't matter. If your entry summaries carry 9903.01.xx lines, you have a claim.

How much could we recover?

Every dollar of IEEPA duty you paid on eligible entries. The refund covers the IEEPA line only, so stacked Section 301 or 232 duty stays paid. Caspian totals it from your ACE data before you commit to anything.

What is CAPE?

CAPE stands for Consolidated Administration and Processing of Entries, the function CBP built inside ACE to process IEEPA refunds in bulk. Phase 1 opened April 20, 2026 for unliquidated entries and entries within 80 days of liquidation. Phase 2 opened June 29. Phase 3 opens October 6 for finally liquidated entries that have a court order to reliquidate.

Can we still file a PSC for IEEPA duty?

No. CBP closed the Post-Summary Correction route for IEEPA refunds. CAPE replaced it, and protests cover the entries CAPE can't reach.

How long do IEEPA refunds take?

CBP targets 60 to 90 days from acceptance of a CAPE declaration, subject to compliance review. It consolidates refunds by recipient and liquidation date, so payments arrive in batches rather than entry by entry.

What if an entry liquidated months ago?

If it liquidated more than 80 days before filing, a protest filed within 180 days of liquidation preserves the refund. Once that window closes, recovery generally runs through the Court of International Trade. Deadlines run whether or not CBP sends notice, which is why Caspian tracks each one.

Do IEEPA refunds affect duty drawback?

They interact. The same dollar of duty can't come back twice, so IEEPA refunds and drawback claims on exported goods have to be sequenced entry by entry. Caspian files both and keeps them from overlapping.

What does Caspian need from us?

Access to your ACE data and a refund ACH account enrolled in ACE. Caspian handles the entry analysis, the CAPE declarations and protests, and the refund tracking.