European Union-origin goods were subject to a 20% IEEPA tariff rate during 2025. The Supreme Court ruled those duties unlawful. The EU-U.S. Framework Agreement, effective July 1, 2026, now caps combined duty rates at 15% — but IEEPA duties paid before that date are 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. Phase 3, covering finally liquidated entries, is targeted for late July 2026.
European luxury brands — French fashion houses, Italian leather goods, German engineered accessories — paid 20% 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 20% IEEPA exposure and strong per-entry refund values.
European automotive imports — German, Italian, Swedish, and French vehicles and parts — faced 20% IEEPA duties stacking on existing tariff structures, creating significant refund exposure.
EU-origin wines, spirits, specialty foods, and agricultural products paid IEEPA duties at 20%. 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. Under DOJ’s current position, Phase 3 is limited to importers who filed individual CIT lawsuits. ~4,000 qualify.
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 [email protected], Monday through Friday, 9 AM – 6 PM Eastern.
With CAPE Phase 3 targeting late July 2026 and statutory interest accruing at approximately $650 million per month industry-wide, every week of delay 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.
Mon–Fri 9am–6pm ET • [email protected]