Direct Answer
Your IEEPA tariff refund equals the IEEPA duty amounts paid on eligible entries plus statutory interest under 19 U.S.C. § 1505, accruing from the payment date. IEEPA rates varied by country and, for some countries, changed significantly over time. Find your actual total by running the Entry Summary Detail Report (ES-003) in ACE and summing the real duty amounts on Chapter 99 HTS codes 9903.01.xx and 9903.02.xx — don't estimate using a single flat rate.
The Supreme Court’s February 20, 2026 ruling in Learning Resources v. Trump opened $166 billion in IEEPA refunds for 330,000 importers of record (the IOR named on CBP Form 7501) across 53 million entry summaries. As of July 10, 2026, $86.3 billion has been repaid to importers and $121.75 billion accepted for processing through CBP’s CAPE system, with statutory interest accruing at approximately $650 million per month under 19 U.S.C. § 1505.
Estimating Your IEEPA Tariff Refund
How much is my IEEPA tariff refund?
Step 1
Identify Your Country of Origin IEEPA Rate — By Date
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 comparatively stable across the period: Vietnam 46%, Cambodia 49%, Thailand 36%, Taiwan 32%. 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.
Step 2
Find Your IEEPA Duty Amounts in ACE
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.
Step 3
Add Statutory Interest
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. Industry-wide, this accrual is approximately $650 million per month across all importers. 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.
Step 4
Separate Phase 1, Phase 2, and Phase 3 Exposure
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.
Step 5
Account for Validation Failure Risk
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.
Common Questions
Frequently Asked Questions
What was the IEEPA tariff rate on China goods?
China's IEEPA rate changed substantially over the eligible period — combined IEEPA duties reached up to 145% at their peak before being reduced to 20% (10% fentanyl + 10% reciprocal) by November 2025. Because the rate varied by date, importers should check the actual duty amount on each entry rather than assuming a flat 20% applied throughout. Only the IEEPA portion is refundable through CAPE — any Section 301 duties remain in effect.
What was the IEEPA rate on Vietnam goods?
Vietnam-origin goods faced a 46% IEEPA rate — one of the highest in the program. The full 46% paid on eligible entries is refundable through CAPE.
How is statutory interest calculated on IEEPA refunds?
Statutory interest under 19 U.S.C. § 1505 accrues from the date IEEPA duties were paid through the date of refund disbursement, at the Treasury-set quarterly interest rate (currently around 6-7% annualized). Interest is included in the consolidated ACH refund payment alongside principal duty recovery.
Is there a minimum refund amount to use CAPE?
No. CAPE has no minimum refund threshold. However, importers with very small refund amounts should weigh the administrative cost of CAPE filing — engaging a contingency advisor (who takes a percentage) may not be economical for refunds under $5,000–$10,000.
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Note: IEEPA duty amounts on your entry summaries may differ from what you expected if your entries were filed under Framework Agreement combined reporting (EU, South Korea, Japan, Switzerland), if Post-Summary Corrections were filed, or if your entries span a period when your country's rate changed (as China's did). Verify with your licensed customs broker before finalizing your refund estimate.
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Informational only. Not legal, tax, or financial advice. The Tariff Bureau LLC is not a law firm, is not a licensed customs broker, and is not affiliated with CBP or any U.S. government agency. The IEEPA statute of limitations accrual date remains legally unsettled. Consult qualified trade counsel for your specific situation.