IEEPA Tariff Refunds: How Importers Can Prepare for the CAPE Refund Process

What is the IEEPA tariff refund process?

Following the Supreme Court's February 20, 2026 ruling in Learning Resources, Inc. v. Trump, which struck down all tariffs imposed under the International Emergency Economic Powers Act (IEEPA), U.S. Customs and Border Protection is building a new electronic system called CAPE (Consolidated Administration and Processing of Entries) to process approximately $166 billion in refunds to more than 330,000 importers of record.

How long will it take to receive an IEEPA tariff refund?

CBP has estimated 45 days to deploy the initial CAPE functionality, with a target go-live in late April 2026. However, the actual timeline for individual refund issuance depends on system readiness, claim volume, and each entry's liquidation status.

The Supreme Court ruled 6-3 that IEEPA does not authorize the President to impose tariffs, invalidating duties that had been collected on over 53 million entries. CBP has described the refund volume as "unprecedented," noting that traditional entry-by-entry liquidation cannot handle the scale. The Court of International Trade initially ordered immediate refunds but suspended that order after CBP outlined its plan for the CAPE system. As of March 19, 2026, CAPE development ranges from 45% to 80% complete across its four components.

Last updated: March 2026

How Does the CAPE Refund System Work?

CBP's CAPE system operates through four integrated stages within the existing Automated Commercial Environment (ACE) platform.

Stage 1: Claim Portal. Importers of record (or their authorized customs brokers) submit refund requests through a centralized ACE portal. Claims are filed using entry-level data via CSV uploads. The portal runs automated validations to confirm that submissions contain all required information, are submitted by the correct importer of record or authorized broker, and contain entries subjected to at least one IEEPA duty. As of March 19, this component was approximately 70% complete.

Stage 2: Mass Processing. Validated entries move into bulk processing, where IEEPA Chapter 99 tariff codes are removed and duty amounts are recalculated without the IEEPA component.

Stage 3: Review and Liquidation/Reliquidation. Entries proceed to liquidation (for unliquidated entries) or reliquidation (for previously liquidated entries that have not become final). Interest calculations are applied during this stage.

Stage 4: Refund Issuance. Rather than processing refunds entry by entry, CBP will consolidate refund amounts by liquidation/reliquidation date and importer of record, then issue payments electronically via ACH to a designated bank account.

CAPE Component	Function	Completion (Mar. 19)
Claim Portal	Submit and validate refund requests	~70%
Mass Processing	Remove IEEPA duties, recalculate	~65%
Liquidation Engine	Schedule and process liquidation	~63%
Refund Aggregation	Consolidate and issue payments	~45%

Source: CBP status report filed March 19, 2026, Atmus Filtration, Inc. v. United States

Which Entries Qualify for IEEPA Refunds?

Not all entries will be processed in CAPE's initial phase. CBP has indicated that the first release will cover the majority of formal and informal entries on which IEEPA duties were paid, but will exclude several categories:

Unliquidated entries subject to antidumping or countervailing duties
Entries with a liquidation status of "Suspended," "Extended," or "Under Review" in ACE
Warehouse withdrawals
Entries designated on a drawback claim
Other complex entry types

CBP plans to address these excluded categories in subsequent CAPE phases. As of early March 2026, approximately 20.1 million of the 53+ million affected entries remained unliquidated, while the remainder had already been liquidated to varying degrees.

Entries that are both liquidated and final present the most complex scenario. CBP's current CAPE framework and the Court of International Trade's orders do not fully address how refunds will be handled for entries where the 180-day protest window has already closed.

What Should Importers Do Right Now to Prepare?

Importers who act early will be best positioned to file claims quickly once CAPE goes live. Key preparation steps include:

Confirm ACE Secure Data Portal access. Ensure your organization has active portal credentials. If you use a customs broker, verify that they have authorization to file on your behalf.
Set up ACH refund authorization. Refunds will be issued electronically. Confirm that your ACH bank information is current and on file with CBP. The CBP ACH Refunds FAQ page provides instructions.
Compile and organize entry data. Begin pulling entry summary identifiers for all entries on which IEEPA duties were deposited. Normalize data across multiple brokers if applicable. CAPE will require CSV-formatted submissions.
Map liquidation status. Categorize your affected entries by liquidation status (unliquidated, liquidated but not final, or final) to understand which entries will be processed in CAPE's first phase versus later phases.
File protests for liquidated entries within the 180-day window. For entries that have been liquidated but not yet become final, filing a protest preserves your refund rights even if CAPE is not yet operational when the protest deadline arrives.
Assess financial reporting impacts. IEEPA duties may have been capitalized into inventory or recognized through cost of goods sold. Finance teams should evaluate how refunds and related interest will be reflected in financial statements.

How Does This Affect the Current Tariff Landscape?

The IEEPA refund process is unfolding alongside a rapidly shifting tariff environment. Hours after the Supreme Court's ruling, President Trump imposed a 10% global tariff under Section 122 of the Trade Act of 1974, a temporary measure limited to 150 days and a maximum rate of 15%. These tariffs took effect February 24 and are set to expire July 24, 2026.

Simultaneously, the administration has launched sweeping Section 301 investigations targeting 16 economies for excess manufacturing capacity and 60 economies for failure to enforce forced labor import bans. These investigations are widely expected to provide the legal foundation for reimposing tariffs similar in scope to the invalidated IEEPA duties.

GingerControl is a trade compliance AI platform that helps importers, exporters, and customs brokers classify products, simulate tariff costs, and track policy changes. For importers managing refund claims alongside new tariff exposure, GingerControl's Tariff Calculator covers the full U.S. tariff stack, including Section 232, Section 301, Chapter 99, and Section 122 tariffs across 200+ countries, making it possible to model your net duty position as refunds arrive and new tariffs take effect.

What Risks Should Importers Watch For?

Several unresolved issues could affect the refund process:

Litigation uncertainty. The Court of International Trade's orders remain subject to appeal. More than 2,000 companies, including Costco and FedEx, have filed lawsuits seeking IEEPA refunds. The government's response to these cases and any appeals could alter the refund timeline or scope.

System capacity under load. Industry analysts have compared the anticipated CAPE filing rush to COVID-era government relief programs, where simultaneous claim surges slowed processing even when systems functioned as designed. With 330,000+ importers potentially filing claims in a compressed window, delays are likely.

Supply chain and commercial agreement implications. Importers of record may need to revisit supplier, customer, or intercompany agreements to determine whether recovered duties are retained, shared, or passed through. Transfer pricing considerations may also arise for multinational organizations.

New tariffs offsetting refunds. Section 122 tariffs are already in effect, and Section 301 tariffs may follow before the 150-day Section 122 window expires. Importers receiving IEEPA refunds should model whether new duties on the same products will partially or fully offset the cash recovery.

FAQ

What is the CAPE system for IEEPA tariff refunds?

CAPE (Consolidated Administration and Processing of Entries) is a new module within CBP's Automated Commercial Environment (ACE) platform. It enables importers and brokers to submit consolidated refund claims for IEEPA duties through a web portal, with automated validation, mass duty recalculation, and electronic refund issuance via ACH.

How much money is being refunded in total?

The estimated total is approximately $166 billion in IEEPA duties collected across more than 53 million entries from over 330,000 importers of record. The exact amount each importer receives depends on their entry-level duty payments and applicable interest.

Do I need to file a claim, or will refunds be issued automatically?

Refunds will not be automatic. Importers of record (or their authorized customs brokers) must submit claims through the CAPE portal in ACE using entry-level data in CSV format. CBP will validate and process these submissions before issuing refunds.

What if my entries have already been liquidated and are final?

This remains an open question. CBP's current CAPE framework and the Court of International Trade's orders do not fully address entries where liquidation is final. Importers with final entries should consult with trade counsel about available options, including any remaining administrative remedies.

Can GingerControl help me track my tariff exposure during the refund process?

GingerControl's Tariff Calculator covers the full U.S. tariff stack, including base duty, Section 232, Section 301, Chapter 99, and Section 122 tariffs. As IEEPA refunds arrive and new tariffs take effect, the calculator helps importers model their net duty position across 200+ countries with date-sensitive calculations. Try the Tariff Calculator

What is the deadline to file for an IEEPA refund?

CBP has not yet announced a formal deadline for CAPE submissions. However, importers with liquidated entries should be aware of the 180-day protest window, which continues to run regardless of CAPE's development timeline. Filing protests within this window preserves refund rights.

Navigating IEEPA refunds alongside new Section 122 and potential Section 301 tariffs requires a clear view of your full duty exposure. GingerControl's Tariff Calculator models every layer of the U.S. tariff stack with date-sensitive precision, so you can plan around both recoveries and new costs.

GingerControl is not just a tool. We work with importers and trade compliance teams on process consulting, digital transformation strategy, and end-to-end custom system development. Talk to our team

References

[REF 1] U.S. Court of International Trade, Atmus Filtration, Inc. v. United States, No. 26-01259 Data cited: CBP status reports on CAPE development (March 12 and March 19, 2026) Source: Court filings referenced in BDO advisory Published: March 2026

[REF 2] Forvis Mazars, "Update on Supreme Court IEEPA Tariff Refund Process" Data cited: CAPE component completion percentages, phased rollout details Source: Forvis Mazars advisory Published: March 2026

[REF 3] Freshfields Bruckhaus Deringer, "Post-IEEPA Tariff Landscape" Data cited: 20.1 million unliquidated entries, Section 122 timeline, Section 301 investigations Source: Freshfields blog Published: March 2026

[REF 4] Grassi Advisors, "U.S. Customs Outlines Four-Step Tariff Refund Process" Data cited: $166 billion total, 330,000 importers, four-step CAPE framework Source: Grassi advisory Published: March 16, 2026

[REF 5] USTR, "Section 301 Investigations: Forced Labor" and "Section 301 Investigations: Excess Capacity" Data cited: 60 economies (forced labor), 16 economies (overcapacity), investigation timelines Source: USTR press release Published: March 12, 2026

[REF 6] Leech Tishman, "CBP Unveils Automated IEEPA Tariff Refund Process" Data cited: Late April 2026 go-live target, phased implementation details Source: Leech Tishman blog Published: March 2026