Tariff Refunds 2026 — Complete Guide

What Are Tariff Refunds?

On February 20, 2026, the Supreme Court ruled 6–3 in V.O.S. Selections Inc. v. United States that IEEPA tariffs were unconstitutional. All IEEPA reciprocal tariffs imposed between April 2025 and February 2026 are now eligible for refund — including the 10% baseline rate and every country-specific rate above it: Vietnam 46%, Cambodia 49%, Thailand 36%, Taiwan 32%, South Korea 25%, EU 20%, and the China 10% reciprocal plus the 10% fentanyl surcharge.

Total refunds owed: approximately $166–175 billion (the higher figure once full statutory interest is calculated) from 330,000+ importers across roughly 53 million shipments. Refunds include statutory interest from the original entry date — 7% per year for individual importers and 6% for corporations, compounded daily under 19 CFR 24.36.

These refunds are not automatic. Importers must affirmatively file to claim every dollar. The Court of International Trade ordered CBP to begin reimbursing importers in March 2026, and CBP opened the CAPE portal on April 20, 2026. The clock starts ticking the day you paid the duty, but the obligation to file is yours.

Who Gets a Tariff Refund?

Only the Importer of Record (IOR) or the specific licensed customs broker who filed the original entries can submit a CAPE Declaration. Not your attorney. Not a new broker you just hired. Not a compliance consultant. The exact party who filed the original CBP Form 7501 entries.

UPS and FedEx began filing automatically on April 21 for shipments where they were the IOR (which covers most consumer parcel imports). Walmart, Target, and Costco are expected to file massive multi-entry claims representing hundreds of millions each. Small businesses need to file themselves through an ACE account or coordinate through the original broker that handled their entries — which means if you switched brokers at any point in the IEEPA window, you need the old one’s cooperation to claim those entries.

Who does not qualify: consumers who bought imported products (even if they paid higher prices because of tariffs), retailers who absorbed tariff costs through higher wholesale prices paid to an importer-distributor, and anyone other than the original IOR or the broker who filed the original entry. Class-action lawsuits seeking direct consumer refunds against Costco, Lululemon, FedEx, UPS, EssilorLuxottica, and Fabletics are pending but will take years.

How Much Could You Get Back?

The math sounds simple. It isn’t. Your refund is the difference between what you paid under IEEPA rates and what you would have paid without them, plus statutory interest. But the actual calculation runs entry by entry, line by line, through CBP’s ACE system — and it depends entirely on the accuracy of the entry data in CBP’s records. Use the estimator below for a ballpark, then understand the real number comes from your 7501s, not from a calculator.

Risks Before You File

CAPE is not a refund line at the bank. CBP is treating it as a front-end intake for a full review and validation process. Five risks every importer should weigh before submitting:

• False Claims Act exposure on inaccurate entries. Filing a CAPE Declaration certifies the underlying entries as accurate. Trade-law firms have explicitly warned that valuation issues, HTS misclassification, or transshipment surfacing during CBP review could trigger separate criminal and civil liabilities.
• CBP offset of other duties owed. CBP has officially confirmed that IEEPA refunds are available to offset amounts owed on other entries — unpaid duties, penalties, liquidated damages, bond claims. The offset happens automatically before any net payment.
• AD/CVD entries require manual processing. Approximately 166,000 entries subject to antidumping and countervailing duty orders ($2.9B in IEEPA duties) are in the slow manual queue. CBP has acknowledged this will dramatically increase workload and result in significant delays for that category.
• The Administration will aggressively contest refunds. Federal Circuit appeal expected by ~June 7. Maximum scrutiny on submissions for compliance issues. Potential challenges to any entries with post-entry modifications.
• No amendment after submission. Once CBP accepts a declaration, it cannot be amended. Errors discovered post-acceptance go to a separate dispute process — or in some cases, get caught in a compliance review that opens broader audit exposure.

Full risk analysis for large importers ($250K+) →

Prerequisites — What You Need Before Filing

Before you can file a CAPE Declaration, you need three things in place. Skip any of them and the refund stops — CBP will not pay an importer who isn’t set up to receive money.

Read the full prerequisite walk-through in our ACE Portal setup guide.

The CAPE Filing Process — More Complex Than It Looks

The CAPE portal opened on April 20, 2026 inside the ACE Secure Data Portal. Here is exactly what filing requires.

Read the full mechanics in our step-by-step CAPE filing guide, and check the day-three update on queue segmentation and the "Unable to calculate duty" error before you upload anything.

Phase 1 vs Phase 2

Phase 1 is live now. It covers unliquidated entries and entries finalized between January 30 and April 19, 2026 — the 80-day window during which an entry can still be protested. Flexport estimates this covers about 63% of all eligible entries.

The remaining 37% — already liquidated and outside the protest window, or tied up in existing protests — must wait for Phase 2. CBP has not announced a Phase 2 timeline. Industry expectation is summer 2026 guidance at the earliest.

If your entries fall outside Phase 1, you are not out of options. You can file formal protests through standard CBP procedures for entries still within 180 days of liquidation, or pursue refund litigation directly in the Court of International Trade. Those are separate processes with their own requirements and deadlines. Either way, preserve every 7501, payment record, and liquidation notice now.

What Is NOT Refundable

Be specific. Many importers assume they’re getting back everything they paid. They’re not.

• Section 232 tariffs — steel 50%, aluminum 50%, autos 25%, copper 50%, semiconductors 25%, lumber 10% — imposed under national security authority. The SCOTUS ruling does not affect them. Not refundable.
• Section 301 tariffs on China — 25% to 100% depending on product — separate legal authority, not touched by the ruling. Not refundable. Anti-dumping and countervailing duties on categories like Chinese passenger and light truck tires (20-87% by producer) are also outside CAPE.
• Section 122 tariff — the current 10% global tariff Trump signed on February 20, 2026 — a completely different legal authority. Not refundable through CAPE. (It faces its own legal challenges in the Court of International Trade, but that’s a separate proceeding.)

Only IEEPA reciprocal tariffs collected between April 2025 and February 24, 2026 are eligible. If you’re calculating what you’ll get back, make sure you’re using only those rates — not your total tariff payments.

Why This Is Harder Than PPP Loans

Remember PPP loans? The government set up an online portal, businesses applied with basic financial documentation anyone could compile, and money came back relatively straightforwardly. CAPE is not PPP.

CAPE requires customs entry summary numbers that many small importers have never looked at, filed through a government trade portal most importers have never used, by a specific party — the original IOR or the filing broker — that may no longer be accessible. The CSV format is unforgiving. The validation rules are strict. The rejection language is not self-explanatory.

CBP originally estimated that processing all eligible IEEPA refunds under its existing manual procedures would require roughly 4.4 million working hours. That’s why CAPE exists — to batch-process declarations algorithmically rather than entry by entry. But CAPE is new, it’s complex, and the 330,000 importers owed money are all trying to use it at once.

The businesses that move fastest and file cleanest get paid first. The businesses that file errors wait longer — or lose specific entries entirely when Phase 1 closes and those entries age past the protest window without a valid claim on file.

Need a Broker to File Your CAPE Declaration?

The CAPE process has no margin for error. One ineligible entry can contaminate your entire declaration. You cannot amend once submitted. Your broker may be backed up for weeks.

If your existing broker is filing CAPE Declarations, start there — they already have your entry data. If they aren’t, or you don’t have a broker, our Find a Customs Broker guide covers what to ask before you engage one.

Our network of licensed professionals has handled government relief program filings at scale. They know CAPE, they know ACE, and they know how to get clean declarations filed without mistakes.