How Much Is My IEEPA Tariff Refund? Calculator & Estimate Guide

IEEPA rates varied by country of origin over the February 2025–February 24, 2026 eligible period, and for some countries the rate itself changed over time. Most notably, China's combined IEEPA duties reached up to 145% at their peak before being reduced to 20% (10% fentanyl + 10% reciprocal) by November 2025 — so a China entry from mid-2025 and one from December 2025 can carry very different IEEPA duty amounts. Other rates were initially announced higher than what was actually sustained — Vietnam and Taiwan, for example, were announced at 46% and 32% respectively, but never took effect at those levels; the sustained rate under Annex I, effective August 7, 2025, was 20% for both. These rates applied on top of existing MFN duties and any applicable Section 301 tariffs — only the IEEPA portion is refundable. Because rates could change mid-period, check the actual duty amount on each entry rather than applying one flat rate across your whole history.

Log into the ACE Secure Data Portal and run the Entry Summary Detail Report (ES-003). Export to Excel. Filter the HTSUS column for Chapter 99 codes beginning with 9903.01 or 9903.02. The duty amount column for each matching row is your IEEPA duty paid on that entry line item. Sum all matching rows across all eligible entries to calculate your gross duty recovery exposure.

Under 19 U.S.C. § 1505, CBP owes interest on late refunds from the date duties were paid. The interest rate is set quarterly by the U.S. Treasury, currently around 6-7% annualized. IEEPA duties paid in early-to-mid 2025 have been accruing interest for well over a year as of mid-to-late 2026. For a rough estimate, add roughly 8-11% to your principal duty amount to account for interest accrued to date — but this varies by exactly when each entry's duty was paid.

Not all your duty exposure is equally recoverable. Phase 1 entries (unliquidated or within 80 days) have the highest recovery confidence — CAPE is actively processing these. Phase 2 entries (reconciliation, no Type 09) are now open but sequence-sensitive. Phase 3 entries (finally liquidated) carry the highest uncertainty — recovery currently depends on CIT plaintiff status. Model these separately for CFO reporting purposes.

Approximately 30% of IEEPA filings have discrepancy issues at the entry level per Gaia Dynamics analysis. Common issues: missing Chapter 99 code on the original entry, wrong tariff authority coding, entry types now excluded (Types 21/22 after July 7). Apply a conservative 15–25% haircut to your gross exposure to estimate net expected recovery before pre-validation.