European Union-origin goods faced a 10% IEEPA baseline rate from April 2025, rising to 15% under the Annex I settled rates effective August 7, 2025 (a structured rate — Column 1 duty plus reciprocal totals 15%, varying by HTS classification). The Supreme Court ruled those duties unlawful. The EU-U.S. Framework Agreement, effective July 1, 2026, now caps combined duty rates at 15% going forward — but IEEPA duties paid during the eligible period remain refundable through CBP's CAPE system.
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The Supreme Court’s February 20, 2026 ruling in Learning Resources v. Trump held that IEEPA tariffs were unlawful, opening $166 billion in refunds across 53 million entry summaries and 330,000 importers of record. U.S. importers of European Union-origin goods are among the eligible. CBP’s CAPE system is actively processing refunds through Phase 1 and Phase 2 — as of its most recent public status update (August 21, 2026), $132.5 billion has been accepted into CAPE and $106.6 billion sent to Treasury for disbursement. Phase 3, covering finally liquidated entries, remains temporarily delayed while CBP builds additional system validations, with no new deployment date announced.
European luxury brands — French fashion houses, Italian leather goods, German engineered accessories — paid IEEPA duties on high-value per-unit imports with significant refund potential per entry.
German, Italian, and EU-origin industrial machinery, precision equipment, and manufacturing tools — high-value entries with significant IEEPA exposure and strong per-entry refund values.
European automotive imports — German, Italian, Swedish, and French vehicles and parts — faced IEEPA duties stacking on existing tariff structures, creating significant refund exposure.
EU-origin wines, spirits, specialty foods, and agricultural products paid IEEPA duties across the eligible period. French, Italian, Spanish, and German producers and their U.S. importers have meaningful per-shipment refund exposure.
CBP is processing IEEPA refunds in three phases. Your eligibility depends on your entry liquidation status and whether a Type 09 reconciliation entry has been filed.
Entries not yet liquidated, or liquidated within 80 days of your CAPE Declaration filing date. Open since April 20, 2026. Applies to all origins including European Union.
Entry Types 01, 02, 06 flagged for reconciliation with no Type 09 filed. Open since June 29, 2026. File CAPE Declaration before Type 09 — sequence matters.
Entries liquidated more than 80 days ago. CBP confirmed August 25, 2026 that Phase 3 remains temporarily delayed while it builds additional reliquidation validations, with no new deployment date given. Once it resumes, a July 17, 2026 CIT order limits it to the roughly 3,700 companies that already filed individual CIT lawsuits.
From eligibility screening to CAPE Declaration delivery — TariffIQ™ handles the analysis, we prep the filing, your licensed broker submits in ACE.
Submit your import profile at tariffbureau.com/assessment. TariffIQ™ screens your European Union-origin entries, HTS codes, and liquidation status against CAPE Phase 1, 2, and 3 eligibility criteria. No obligation.
We build a CFO-ready financial model of your recoverable European Union-origin IEEPA duties plus statutory interest under 19 U.S.C. § 1505. You see your recovery estimate before signing anything.
We build your CAPE Declaration CSV, validate Chapter 99 HTS codes on your European Union-origin entries, check ACH enrollment status in ACE, and verify filing sequence. Your licensed customs broker submits in ACE.
No recovery, no fee. We take a percentage of the refund when CBP pays. If you don’t recover, you owe nothing. The Form 4811 designee model means your ACH refund can flow directly through our account for disbursement.
The Tariff Bureau serves U.S. importers of EU-origin goods remotely through our digital engagement platform. No office visit required. Submit your free assessment at tariffbureau.com/assessment and receive a TariffIQ™ eligibility report within minutes. For direct assistance, reach us at (404) 882-5839 or hello@tariffbureau.com, Monday through Friday, 9 AM – 6 PM Eastern.
With CAPE Phase 3 still delayed and statutory interest continuing to accrue on unpaid IEEPA duties industry-wide, every week before you file reduces your total recovery. The earlier your CAPE Declaration is filed and validated, the more interest you collect.
TariffIQ™ identifies your exact CAPE phase position, your refund estimate, and your next step. Free assessment, no obligation, no recovery no fee.
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