🟢 CAPE PHASE 2 LIVE: June 29, 2026 — Reconciliation entries now eligible. File CAPE before Type 09 to preserve eligibility.  |  $130B+ now processing combined
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IEEPA Tariff Refund Recovery — Advisory Services

IEEPA Tariff
Refund Recovery
for U.S. Importers

CAPE Phase 2 launched June 29, 2026, opening reconciliation entries to refund eligibility. Combined with Phase 1, roughly $130 billion of the $166 billion IEEPA refund pool is now processing through CBP CAPE. The Tariff Bureau handles everything from eligibility screening through claim submission — including the filing-sequence trap that can knock entries out of Phase 2.

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$130B
Combined Phase 1 + Phase 2 processing through CBP CAPE — June 29, 2026
$166B
Total IEEPA tariff refund pool — SCOTUS ruling Feb. 2026
2.8M
Reconciliation entries newly eligible under CAPE Phase 2
Filing Order
File CAPE before Type 09 — or drop out of Phase 2 into a later, slower phase
What Is IEEPA Tariff Refund Recovery

CAPE Phase 2 just opened
$28.7 billion in new eligibility.

In February 2026, the U.S. Supreme Court ruled in Learning Resources, Inc. v. Trump that the IEEPA tariffs — both the February 2025 trafficking tariffs on Canada, Mexico, and China and the April 2025 reciprocal tariffs — were unlawfully levied. This ruling entitled approximately 330,000 U.S. importers to reclaim those duties in full — plus interest.

CBP launched the CAPE portal on April 20, 2026 (Phase 1) to process refund claims, and opened Phase 2 on June 29, 2026, extending eligibility to reconciliation-flagged entries (entry types 01, 02, and 06) where no Type 09 reconciliation entry has been filed yet. CBP estimates Phase 2 covers approximately 2.8 million entries and $28.7 billion in potential refunds, bringing combined Phase 1 and Phase 2 coverage to roughly $130 billion of the $166 billion total pool.

The barriers remain real: ACE portal complexity, HTS classification review requirements, the False Claims Act certification risk on every CAPE Declaration — and now, for Phase 2 specifically, a filing-sequence trap: file your Type 09 reconciliation entry before your CAPE Declaration, and that entry drops out of Phase 2 into a later, slower phase.

The Tariff Bureau was built specifically to close this gap — from eligibility screening through full claim recovery, including correct filing sequencing — for mid-market U.S. importers and DDP foreign manufacturers.

Who Qualifies for IEEPA Tariff Refunds

Your company may be eligible under Phase 1, Phase 2, or both if you meet these criteria:

✓
You imported goods subject to IEEPA tariffs — trafficking or reciprocal — between early February 2025 and February 2026
✓
Your company is the Importer of Record on the CBP entry summaries for those shipments
✓
Your entries are unliquidated or liquidated within the 80-day CAPE window (Phase 1 or Phase 2), or your entries are finally liquidated (180+ days) and require an individual CIT case
✓
For Phase 2 specifically: your entries are flagged for reconciliation (types 01, 02, 06) and no Type 09 reconciliation entry has been filed yet
✓
You have an active ACE Secure Data Portal account or can establish one through a licensed customs broker

What Tariffs Are NOT Eligible

CAPE refunds apply only to IEEPA tariffs. The following are not eligible for CAPE recovery:

✕
Section 232 tariffs — steel, aluminum, and automobiles
✕
Section 301 tariffs — tariffs on China imposed before the IEEPA period
✕
Section 122 global tariff — the 10% global tariff effective February 24, 2026, expiring July 24, 2026 (ruled unlawful by the CIT May 7 for three plaintiff importers; stayed on appeal — still collected)

IEEPA Refund Recovery Services

The Tariff Bureau offers six advisory tiers structured around the full refund recovery lifecycle:

IEEPA Eligibility Screening
4-qualifier written eligibility determination, including Phase 1/Phase 2 filing sequence check. Credited toward full engagement.
$1,500 flat
Full Recovery Package
End-to-end CAPE enrollment, documentation, and claim strategy.
$4K base + 12–15%
Claim Audit & Optimization
Pre-submission review for $250K+ claims. Mitigates False Claims Act risk.
$6K–$15K flat
Tariff Risk Assessment
Classification review, origin documentation, and CAPE eligibility analysis.
$8K–$18K flat
Rerouting Analysis
Supplier diversification and country-of-origin restructuring.
$10K–$40K
Monitoring Retainer
Ongoing trade intelligence and regulatory alerts via TariffIQ.
$3K–$10K/mo

View full pricing details →

Start Your IEEPA Refund Assessment

Find out if your entries qualify under Phase 1, Phase 2, or both — structured intake reviewed by TariffIQ.

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(404) 882-5839
🟢 Phase 2 Live
June 29, 2026
File your CAPE Declaration before your Type 09 reconciliation entry — once Type 09 is filed, that entry falls out of Phase 2 and into a later, slower phase.
Frequently Asked Questions

IEEPA Refund Recovery —
What Importers Ask

Answers to the most common questions about IEEPA tariff refunds, the CBP CAPE portal, and The Tariff Bureau’s advisory services.

What is IEEPA tariff refund recovery?
IEEPA tariff refund recovery is the process of reclaiming duties paid under the International Emergency Economic Powers Act (IEEPA) tariffs that the U.S. Supreme Court ruled unlawful in February 2026 in Learning Resources, Inc. v. Trump. Eligible U.S. importers file CAPE Declarations through the CBP CAPE portal to recover IEEPA tariffs paid between early February 2025 and February 2026.
How much can my company recover?
The total IEEPA refund pool is estimated at $166 billion across approximately 330,000 eligible U.S. importers. CAPE Phase 1 and Phase 2 combined now cover roughly $130 billion of that pool. Per CBP’s July 1, 2026 CIT status declaration, approximately $71.06 billion in refunds had already been certified and sent to Treasury as of June 29. Individual recovery depends on total IEEPA duty paid, number of eligible entries, HTS classification accuracy, and whether entries fall within the 80-day CAPE liquidation window or require individual CIT action.
What is the CBP CAPE portal, and what is Phase 2?
CAPE (Consolidated Administration and Processing of Entries) is a CBP system launched April 20, 2026 (Phase 1) inside the ACE Secure Data Portal. Phase 2 launched June 29, 2026, per CSMS #69066837, extending eligibility to reconciliation-flagged entries (types 01, 02, 06) where no Type 09 reconciliation entry has been filed. It allows importers of record and licensed customs brokers to file CAPE Declarations and claim IEEPA tariff refunds. CBP projects 60–90 day processing once a claim is accepted.
What are the deadlines and traps I need to know?
Several apply. First, the 80-day liquidation window: CAPE Phase 1 and Phase 2 accept entries that are unliquidated or liquidated within 80 days. Entries liquidated more than 80 days ago when the relevant phase opens fall outside that phase's scope. Second, the filing-sequence trap unique to Phase 2: if you file your Type 09 reconciliation entry before your CAPE Declaration, the underlying entries drop out of Phase 2 and into a later, slower phase. If your reconciliation deadline is under 30 days away, CBP guidance says file the Type 09 first. Third, finally liquidated entries (180+ days) currently require an individual CIT case under CBP's position — they are not covered by Phase 1 or Phase 2.
What is the False Claims Act risk in CAPE filings?
Every CAPE Declaration requires the importer to certify that all entry summaries comply with applicable law. If a customs broker misclassified goods and the importer certifies the claim, that constitutes a false claim under the False Claims Act. CBP uses AI and the DOJ-DHS Trade Fraud Task Force to audit filings. Large claims face heightened audit scrutiny. The Tariff Bureau’s Claim Audit & Optimization service reviews your entries before you certify.
Can foreign manufacturers recover IEEPA tariffs?
Foreign manufacturers selling under DDP (Delivered Duty Paid) terms may have absorbed IEEPA tariff costs into their pricing or margins. The Tariff Bureau advises DDP exporters from Vietnam, Taiwan, South Korea, India, Bangladesh, and Indonesia on IOR advisory, CAPE enrollment options, and rerouting analysis to reduce ongoing exposure.
Does Phase 2 cover my reconciliation entries automatically?
Not always. Entries filed before approximately May 31, 2025 that liquidated on the standard 314-day reconciliation cycle have already exceeded the 80-day window and fall outside Phase 2, regardless of reconciliation status. The Tariff Bureau was built to identify exactly which of your reconciliation entries are Phase 2-eligible versus which require a different track.
How does The Tariff Bureau charge for refund recovery?
The Tariff Bureau offers an IEEPA Eligibility Screening for $1,500 flat — a 4-qualifier written determination, including Phase 1/Phase 2 filing-sequence review, credited toward any full engagement. Full Recovery Package engagements start at $4,000 base plus 12–15% contingency on recovered amounts. Minimum $50,000 estimated recovery required for full engagements. View full pricing →
IEEPA Resource Library
IEEPA Tariff FAQ IEEPA Glossary IEEPA HTS Codes Protest vs. Refund CAPE Portal Deadlines CBP Refund Process Federal Circuit Appeal DDP Foreign Manufacturers For Importers & CFOs For Lenders Supply Chain Recovery Contingency Model China Imports Vietnam Imports Taiwan Imports South Korea Imports India Imports EU Imports Atlanta Importers

Phase 2 is open.
Filing order matters.

$130B+ is now processing combined across CAPE Phase 1 and Phase 2. The Tariff Bureau is taking intake today — including a filing-sequence check to protect your Phase 2 eligibility.

Begin Your Intake → Free Assessment
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