China IEEPA Tariff Refund Recovery
If your business imported goods from China subject to IEEPA tariff orders, a federal court has ruled those duties must be refunded. CBP’s CAPE system is now processing claims — Phase 3 is live as of October 6, 2026.
The IEEPA tariff orders issued in 2025 targeted goods imported from China more heavily than any other country — with rates reaching 145% on many HTS categories including electronics, machinery, textiles, chemicals, and consumer goods. Billions in duties were collected before the Federal Circuit Court of Appeals ruled the tariff program exceeded executive authority and ordered full refunds.
If your company imported from China between the effective date of the tariff orders and the court’s refund mandate, you are likely entitled to recover those duties through CBP’s Collection Action Processing Environment (CAPE).
The IEEPA refund program covers all entries of Chinese-origin goods subject to the tariff orders, including — but not limited to:
Coverage depends on the specific HTS codes on your entry summaries, the country-of-origin determination for each shipment, and whether entries have been liquidated. CAPE Phase 3 specifically extends eligibility to finally liquidated entries — a significant expansion from earlier phases.
CBP’s Collection Action Processing Environment launched in phases. Phase 3, which went live October 6, 2026, is the most consequential for importers of Chinese goods because it opens the refund window to finally liquidated entries — entries where CBP has issued a final duty assessment. Most high-volume importers from China will have a significant portion of their IEEPA exposure sitting in finally liquidated status.
Covered unliquidated and protest-eligible entries. Importers who filed early protests or had open entries were first to receive disbursements from the $134.7B pool.
Finally liquidated entries are now eligible. This is the largest tranche for most China importers. CBP has disbursed $122B to date — the window is moving fast.
CBP is processing entries in liquidation-date order. Waiting means your entries fall further back in the queue. Filing now preserves your position in the disbursement timeline.
The Tariff Bureau pulls your Customs Form 7501 entry summaries, identifies all China-origin entries subject to the IEEPA tariff orders, and calculates your total refund exposure by HTS code and entry date.
We determine which of your entries are finally liquidated, unliquidated, or protest-eligible, and route each category to the correct CAPE phase or CBP filing track. Getting this classification right is critical — incorrect routing delays or forfeits your refund.
All CAPE filings are coordinated with or executed through a licensed customs broker in accordance with 19 C.F.R. Part 111. We prepare the complete submission package — entry numbers, duty amounts, supporting documentation — and manage all CBP correspondence through disbursement.
Once CBP approves your claim, refunds are disbursed directly to the importer of record. We reconcile each payment against your entry summary audit and flag any shortfalls for follow-up.
Many China importers used first-sale valuation on their entry summaries. If the IEEPA tariff was assessed on a different dutiable value than the first-sale price, your refund calculation must account for this discrepancy or CBP will process on the wrong basis.
Some goods assembled in China from third-country components may have mixed country-of-origin determinations. We review Customs Form 434 and any binding rulings on file to confirm which entries qualify under the refund order.
Entries withdrawn from bonded warehouses or Foreign Trade Zones during the IEEPA tariff period require separate documentation. CBP’s CAPE filing requirements for these entry types differ from standard consumption entries.
If your business changed its importer of record designation, acquired a company that imported from China, or restructured during the tariff period, the refund claim must be filed under the correct IOR — CBP will not automatically transfer refund rights across IOR changes.
Advisory only — not legal advice. Customs brokerage services are coordinated with or executed through a licensed customs broker in accordance with 19 C.F.R. Part 111. The Tariff Bureau LLC is not itself a licensed customs broker. Governing law: Georgia. Arbitration: Fulton County, GA.
U.S. importers paid billions in IEEPA tariffs on Chinese goods that a federal court has ordered refunded. CAPE Phase 3 is now live — act before CBP processing windows close.
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