IEEPA Tariff Refunds — How to Claim Your Money (April 2026)

What Happened: CAPE Portal Launches April 20, 2026

CBP launched the Consolidated Administration and Processing of Entries (CAPE) portal on April 20, 2026, at 8 a.m. EST. CAPE lives inside the ACE (Automated Commercial Environment) Secure Data Portal — the same system importers already use for entry filings. The launch follows the Supreme Court's February 20, 2026 ruling in V.O.S. Selections Inc. v. United States, which held 6-3 that IEEPA does not authorize tariffs. In March, the Court of International Trade ordered the administration to begin reimbursing importers. Total IEEPA duties collected from April 2025 through February 2026 add up to approximately $166 billion from over 330,000 importers across 53 million shipments. CBP has confirmed that about 82% of that total — roughly $127 billion including statutory interest — is eligible for refund in Phase 1. The remaining ~18% sits in older liquidated entries that will either wait for Phase 2 or need to be pursued directly through the Court of International Trade.

How to File for an IEEPA Refund (Step by Step)

The filing workflow runs entirely through the ACE Portal. Step 1: Register for an ACE Secure Data Portal account at ace.cbp.dhs.gov if you don't already have one. ACE account applications take up to a month — if you don't have one, apply immediately at ace.cbp.dhs.gov. The 30-day clock starts when you submit Form 5106, not when you remember to start. Step 2: Enroll in ACH for electronic refunds — this is required. Fewer than 10% of eligible importers had completed ACH enrollment as of early March, weeks before the portal opened — most are scrambling now. CBP will not issue refund checks; payments must go to a US bank account via ACH, manually added to your Importer sub-account. Step 3: Prepare a CAPE Declaration. This is a CSV file that lists every entry number you want refunded. Both liquidated and unliquidated entries can be included on the same Declaration. Step 4: Log into ACE, navigate to the new CAPE tab, and upload your CAPE Declaration file. Step 5: Wait for CBP validation. CBP runs two rounds of checks — first at the declaration level (file formatting, importer identity, ACH status), then at the entry level (does each entry actually qualify, what rate applies, is it unliquidated or within the 80-day window). Once accepted, your Declaration receives a unique CAPE claim number — track status via the REV-615 CAPE Refunds Trade Report in your ACE Portal. Unliquidated entries are scheduled to liquidate 45 days after Declaration acceptance. Already-liquidated entries within the 80-day window are reliquidated the next business day after acceptance. Step 6: Refunds issue via ACH within 60 to 90 days of Declaration acceptance, as one lump sum per IOR per liquidation date — not entry by entry. Under the hood, CBP's refund math is straightforward once a declaration is accepted: the system strips the IEEPA Chapter 99 HTS numbers off each entry summary, recalculates the duty as if IEEPA had never been imposed, and cuts a refund for the difference. Statutory interest is automatic under 19 CFR 24.36 — currently 7% per year for individual importers and 6% for corporations, compounded daily from the date CBP originally collected the duty. You don't calculate it; CBP does.

Non-Resident Importers: Additional ACH Barrier

If you are a non-resident importer (NRI) operating in the US without US banking infrastructure, your approved CAPE refund may face payment delays even after acceptance. CBP's ACH system requires valid US bank account details. NRIs operating through domestic subsidiaries or agents should confirm their ACE account is configured to receive ACH payments to a US account before submitting.

This issue is just now coming to light as early CAPE submissions begin processing. Baker Tilly flagged it on April 29: NRIs without US banking can have a clean, accepted CAPE Declaration and still see refund payment sit in limbo because the ACH disbursement has nowhere to go.

If you import as an NRI, do this before filing: confirm the ACH bank details under your Importer sub-account in ACE point to a US account that can receive the payment. If your operations run through a domestic subsidiary or customs broker acting as agent, work with that entity's banking on the ACH leg. CBP cannot work around the ACH requirement for any importer, resident or non-resident — the system pays the bank account on file or it does not pay at all.

What the First Few Days Have Actually Looked Like

The launch has been rocky, predictably. CBP confirmed to CBS News that it's investigating reports of portal errors — including a "Duplicate tax ID" message that appears when an importer's EIN is tied to another account in ACE's backend. Submission delays and portal congestion are turning up across broker desks, trade forums, and LinkedIn, which isn't a surprise for a system processing something on the order of $127 billion in Phase 1 claims in its first week. The practical takeaway: don't treat a submission as filed until you see a declaration ID in ACE and the REV-615 CAPE Refunds Trade Report picks it up. REV-615 went live with the portal and is how you verify what's actually been accepted, flagged, or rejected — accepting that your broker said "it went through" is not the same thing. CBP is also running live CAPE support webinars on April 28 at 1 p.m. ET (the April 21 session has already taken place). If your staff is new to the portal, send them — CBP is answering in real time the same questions that are showing up as batch-file rejections.

Who Qualifies for Phase 1

Phase 1 covers only two categories of entries: (1) unliquidated entries — entries CBP has not yet finalized, which is most entries from the last 10-12 months, and (2) entries that have been liquidated but are still within 80 days of liquidation, which is the statutory window for filing a protest under 19 U.S.C. § 1514. Older liquidated entries fall outside Phase 1 and will need to wait for later phases or be pursued directly through the Court of International Trade. Only the Importer of Record (IOR) — or a licensed customs broker filing on the IOR's behalf with a valid Power of Attorney — can file a CAPE Declaration. Each declaration can include up to 9,999 entries. Large importers can submit multiple declarations. But there's a hard rule: once a declaration is accepted, it cannot be amended, and any entry already on an accepted declaration cannot be submitted on another. Plan the grouping carefully.

What Gets Refunded (and What Doesn't)

CAPE Phase 1 refunds all duties paid under IEEPA authority — that is, the reciprocal tariffs that took effect April 5, 2025 and the adjusted country-specific rates that took effect August 1, 2025. That covers both the 10% baseline reciprocal tariff and all country-specific rates above 10% (Vietnam 46%, Thailand 36%, Taiwan 32%, South Korea 25%, EU 20%, the China 10% reciprocal + 10% fentanyl surcharge, and every other IEEPA rate). Refunds include statutory interest from the original entry date. What does NOT get refunded: Section 232 tariffs on steel (50%), aluminum (50%), autos (25%), copper (50%), semiconductors (25%), and lumber (10%) — these were imposed under national security authority and were not part of the SCOTUS ruling. Section 301 tariffs on China (25-100%, product-specific) also remain — imposed under separate trade law authority. And critically, the current 10% Section 122 tariff — Trump's replacement signed on February 20, 2026 — is NOT refundable. Section 122 is a different legal authority, still in force, and still being collected.

Key Warnings for Importers Filing in Phase 1

The CAPE process is unforgiving about errors. Warning #1: If any entry on your CAPE Declaration doesn't qualify — wrong entry type, already liquidated beyond 80 days, not actually IEEPA-paid — CBP may reject the ENTIRE declaration, not just the bad line. Double-check every entry number before submitting. Warning #2: You cannot amend a declaration after submission. If you left entries off, file a second declaration for those, but you can't fix an accepted one. Warning #3: Entries already on an accepted declaration cannot be resubmitted. One shot per entry. Warning #4: Phase 1 only covers unliquidated entries and entries within 80 days of liquidation. Older entries — particularly those from April through August 2025 that have already liquidated and passed the protest window — will need to wait for later CAPE phases or be pursued through the Court of International Trade. Warning #5: The administration has publicly hinted it may try to offset refund amounts using alternative tariff authorities or claw back portions of what's owed. Treasury Secretary Bessent predicted the process 'could be a mess' lasting months or years. File promptly and document everything. Warning #6: Some importers will fall into gaps CAPE doesn't cover — for them, a CIT filing with legal representation is the realistic path.

Do You Need a Customs Broker?

Legally, no — an Importer of Record can file a CAPE Declaration directly through ACE. Practically, if you import at any scale, use your broker. Brokers already have your entry data, already filed the original 7501 entries that paid the IEEPA duty, and already know the rejection patterns that trip up first-time filers. For an importer with hundreds or thousands of entries across the 10-month IEEPA window, broker automation is the difference between filing one well-formed CSV and manually reconciling entry numbers for weeks. Fees vary — expect per-entry CAPE filing fees on top of original brokerage, though several large brokers (Livingston, Expeditors, CH Robinson) have announced flat-rate or capped CAPE pricing for existing customers. If you have 10 or fewer entries, self-filing through ACE is feasible. If you have hundreds, delegate. See /find-a-customs-broker for the four questions to ask before you engage one.

How Long Until You Get Paid

CBP's stated processing time is 60 to 90 days after a CAPE Declaration is accepted. "Accepted" means it passed both validation rounds — declaration-level and entry-level — which itself can take 2–4 weeks after submission, and launch-week congestion is pushing some filers to the longer end of that window before they've even started the official processing clock. Realistic expectation for an importer filing a clean declaration in late April 2026: funds arrive via ACH somewhere between mid-July and mid-August. Rejected declarations reset the clock — if CBP bounces your file for a single bad entry, you pull that entry, resubmit the declaration, and the 60–90 day window restarts from the new acceptance date. The one consolation: statutory interest keeps accruing through the delay at 7% (individual) or 6% (corporate) compounded daily, so time in queue isn't money lost — but it's not cash in hand either. Treasury Secretary Bessent has publicly warned the process "could be a mess" and may extend longer than CBP's stated timelines. Plan cash flow assuming Q3 or Q4 2026, not "by June."

Will Consumers Get Refunds?

Short answer: no, not directly. Refunds under CAPE go to the Importer of Record — the company that paid the duty at the port of entry. Consumers paid those tariffs indirectly, buried in higher wholesale and retail prices, but they have no direct CBP claim. A few companies have put their pass-through position on the record. FedEx has been the most explicit — a spokesperson told reporters, "if refunds are issued to FedEx, we will issue refunds to the shippers and consumers who originally bore those charges." Costco has said it intends to pass savings to shoppers through lower pricing rather than mailing checks. The rest of the Fortune 500 has mostly gone quiet: Money magazine asked 19 major companies about refund plans in April and only three replied. Meanwhile, the class-action list has expanded well beyond the initial Costco and FedEx filings and now includes Lululemon, UPS, EssilorLuxottica (the eyewear giant behind Oakley and Ray-Ban), and Fabletics. The plaintiffs' core argument is consistent: companies already collected the tariff cost from consumers as higher prices, and pocketing the refund on top is a "duplicate benefit." Those cases will take years. Realistically, most US consumers will not see a refund check — the $166 billion flows back to importers, and how much reaches end customers depends entirely on each company's pricing decisions. Expect the downstream effect to show up as gradual retail pricing softening in 2026–2027, not checks in the mail.

What About Phase 2 and Later Entries?

Phase 1 is intentionally narrow — it covers the cleanest cases (unliquidated entries and recent liquidations) to get money moving fast. CBP has indicated Phase 2 will extend to older liquidated entries, but no launch date has been announced. Expect guidance in summer 2026. Entries that fall entirely outside CAPE — for example, very old liquidations or complex cases with surety disputes — will likely need to be pursued through the Court of International Trade with legal representation. If you have significant entries from April through August 2025 that have already liquidated and passed the 80-day protest window, start preparing now: pull all your 7501s, payment records, and liquidation notices. When Phase 2 opens, the importers with organized records will file first and get paid first.

What to Do Right Now (Action Checklist)

Step 1: Confirm ACE Secure Data Portal access. If you're an IOR and don't have an account, register today. Step 2: Enroll in ACH for electronic refunds — without this, nothing moves. Step 3: Pull a list of every entry you filed between April 5, 2025 and February 24, 2026 that paid IEEPA duty. Sort by liquidation status. Step 4: Identify which entries qualify for Phase 1 (unliquidated or within 80 days of liquidation). Step 5: Contact your customs broker. If they have a CAPE filing service, get on their queue early — the launch week surge will bottleneck processing. Step 6: For entries outside Phase 1, preserve all documentation (7501, proof of payment, liquidation notice) and wait for Phase 2 guidance. Step 7: Do not rely on the current Section 122 10% tariff being refunded — it's a different legal authority and not part of this proceeding. Step 8: Subscribe to CBP's IEEPA refund email list for Phase 2 announcements and rule changes.