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 ranged from 10–46% of customs value by country. Find your total by running the Entry Summary Detail Report (ES-003) in ACE and summing the duty amounts on Chapter 99 HTS codes 9903.01.xx and 9903.02.xx.
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 June 29, 2026, $71.06 billion has been certified and sent to Treasury 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
IEEPA rates varied by country of origin during the March 2025–February 24, 2026 duty period. Key rates: China 20%, Taiwan 32%, Vietnam 46%, South Korea 25%, India 18%, European Union 20%, Cambodia 49%, Thailand 36%. These rates applied on top of existing MFN duties and any applicable Section 301 tariffs. Only the IEEPA portion is refundable.
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. IEEPA duties paid in mid-2025 have been accruing interest for over a year as of mid-2026. Industry-wide, this accrual is approximately $650 million per month across all importers. For a rough estimate, add 5–8% to your principal duty amount to account for interest accrued through mid-2026.
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 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-origin goods faced a 20% IEEPA rate on top of existing MFN and Section 301 duties during the March 2025–February 24, 2026 period. Only the IEEPA 20% is refundable through CAPE — 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. 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) or if Post-Summary Corrections were filed. 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.