🟢 PHASE 2 LIVE — July 24: Section 122 expired, replaced same-day by new Section 301 tariffs (10–12.5%) on 60 countries  |  $86.3B repaid, $121.75B accepted through CAPE as of July 10
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IEEPA Tariff Refund Recovery — Advisory Services

IEEPA Tariff
Refund Recovery
for U.S. Importers

CBP has repaid $86.3 billion and accepted $121.75 billion of the $166 billion IEEPA refund pool as of its July 10, 2026 court declaration. Phase 1, Phase 2, and now Phase 3 (finally liquidated entries, for CIT plaintiffs only pending the government's Federal Circuit appeal) are all live. The Tariff Bureau handles everything from eligibility screening through claim submission — including the filing-sequence trap that can knock entries out of Phase 2, and the CIT filing decision that determines Phase 3 eligibility.

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$86.3B
Repaid to importers through CBP CAPE — per July 10, 2026 court declaration
$166B
Total IEEPA tariff refund pool — SCOTUS ruling Feb. 2026
$121.75B
Total accepted into CAPE for processing as of July 10, 2026
Filing Order
File CAPE before Type 09 — or drop out of Phase 2 into a later, slower phase
What Is IEEPA Tariff Refund Recovery

$121.75 billion accepted.
Phase 3 now open for CIT filers.

In February 2026, the U.S. Supreme Court ruled in Learning Resources, Inc. v. Trump that the IEEPA tariffs — both the February 2025 trafficking tariffs on Canada, Mexico, and China and the April 2025 reciprocal tariffs — were unlawfully levied. This ruling entitled approximately 330,000 U.S. importers to reclaim those duties in full — plus interest.

CBP launched the CAPE portal on April 20, 2026 (Phase 1) to process refund claims, opened Phase 2 on June 29, 2026, extending eligibility to reconciliation-flagged entries (entry types 01, 02, and 06) where no Type 09 reconciliation entry has been filed yet, and brought Phase 3 into effect following a July 17, 2026 CIT order directing CBP to reliquidate finally liquidated entries — currently limited to the roughly 3,700 companies that already filed their own CIT lawsuit, pending the government's Federal Circuit appeal (opening brief due August 3, 2026). Per CBP's July 13, 2026 court declaration, $121.75 billion has been accepted into CAPE and $86.3 billion has already been repaid to importers, out of the $166 billion total pool.

The barriers remain real: ACE portal complexity, HTS classification review requirements, the False Claims Act certification risk on every CAPE Declaration — and now, for Phase 2 specifically, a filing-sequence trap: file your Type 09 reconciliation entry before your CAPE Declaration, and that entry drops out of Phase 2 into a later, slower phase.

The Tariff Bureau was built specifically to close this gap — from eligibility screening through full claim recovery, including correct filing sequencing — for mid-market U.S. importers and DDP foreign manufacturers.

Who Qualifies for IEEPA Tariff Refunds

Your company may be eligible under Phase 1, Phase 2, or both if you meet these criteria:

✓
You imported goods subject to IEEPA tariffs — trafficking or reciprocal — between early February 2025 and February 2026
✓
Your company is the Importer of Record on the CBP entry summaries for those shipments
✓
Your entries are unliquidated or liquidated within the 80-day CAPE window (Phase 1 or Phase 2), or your entries are finally liquidated (more than 80 days past liquidation) and you've filed — or are prepared to file — an individual CIT case, which Phase 3 now requires
✓
For Phase 2 specifically: your entries are flagged for reconciliation (types 01, 02, 06) and no Type 09 reconciliation entry has been filed yet
✓
You have an active ACE Secure Data Portal account or can establish one through a licensed customs broker

What Tariffs Are NOT Eligible

CAPE refunds apply only to IEEPA tariffs. The following are not eligible for CAPE recovery:

✕
Section 232 tariffs — steel, aluminum, and automobiles
✕
Section 301 tariffs — tariffs on China imposed before the IEEPA period
✕
Section 122 / Section 301 tariffs — the 10% Section 122 global tariff expired by statute on July 24, 2026, and was replaced the same instant by new Section 301 tariffs of 10–12.5% on roughly 60 countries. Neither is refundable through CAPE.

IEEPA Refund Recovery Services

The Tariff Bureau offers six advisory tiers structured around the full refund recovery lifecycle:

IEEPA Eligibility Screening
4-qualifier written eligibility determination, including Phase 1/Phase 2 filing sequence check. Credited toward full engagement.
$1,500 flat
Full Recovery Package
End-to-end CAPE enrollment, documentation, and claim strategy.
$4K base + 12–15%
Claim Audit & Optimization
Pre-submission review for $250K+ claims. Mitigates False Claims Act risk.
$6K–$15K flat
Tariff Risk Assessment
Classification review, origin documentation, and CAPE eligibility analysis.
$8K–$18K flat
Rerouting Analysis
Supplier diversification and country-of-origin restructuring.
$10K–$40K
Monitoring Retainer
Ongoing trade intelligence and regulatory alerts via TariffIQ.
$3K–$10K/mo

View full pricing details →

Start Your IEEPA Refund Assessment

Find out if your entries qualify under Phase 1, Phase 2, or both — structured intake reviewed by TariffIQ.

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(404) 882-5839
🟢 Phase 1, 2 & 3 Live
Updated July 30, 2026
File your CAPE Declaration before your Type 09 reconciliation entry — once Type 09 is filed, that entry falls out of Phase 2 and into a later, slower phase. Finally liquidated entries now need a filed CIT case to access Phase 3.
Frequently Asked Questions

IEEPA Refund Recovery —
What Importers Ask

Answers to the most common questions about IEEPA tariff refunds, the CBP CAPE portal, and The Tariff Bureau’s advisory services.

What is IEEPA tariff refund recovery?
IEEPA tariff refund recovery is the process of reclaiming duties paid under the International Emergency Economic Powers Act (IEEPA) tariffs that the U.S. Supreme Court ruled unlawful in February 2026 in Learning Resources, Inc. v. Trump. Eligible U.S. importers file CAPE Declarations through the CBP CAPE portal to recover IEEPA tariffs paid between early February 2025 and February 2026.
How much can my company recover?
The total IEEPA refund pool is estimated at $166 billion across approximately 330,000 eligible U.S. importers. Per CBP’s July 13, 2026 CIT status declaration, approximately $121.75 billion has been accepted into CAPE and $86.3 billion has already been repaid to importers as of July 10. Individual recovery depends on total IEEPA duty paid, number of eligible entries, HTS classification accuracy, and whether entries fall within the 80-day CAPE liquidation window or require individual CIT action.
What is the CBP CAPE portal, and what is Phase 2?
CAPE (Consolidated Administration and Processing of Entries) is a CBP system launched April 20, 2026 (Phase 1) inside the ACE Secure Data Portal. Phase 2 launched June 29, 2026, per CSMS #69066837, extending eligibility to reconciliation-flagged entries (types 01, 02, 06) where no Type 09 reconciliation entry has been filed. Phase 3 (finally liquidated entries) is now in effect following a July 17, 2026 CIT order, but currently only for the roughly 3,700 companies that already filed their own CIT lawsuit — the government's Federal Circuit appeal of the broader refund order is pending, with an opening brief due August 3, 2026. It allows importers of record and licensed customs brokers to file CAPE Declarations and claim IEEPA tariff refunds. CBP projects 60–90 day processing once a claim is accepted.
What are the deadlines and traps I need to know?
Several apply. First, the 80-day liquidation window: CAPE Phase 1 and Phase 2 accept entries that are unliquidated or liquidated within 80 days. Entries liquidated more than 80 days ago when the relevant phase opens fall outside that phase's scope. Second, the filing-sequence trap unique to Phase 2: if you file your Type 09 reconciliation entry before your CAPE Declaration, the underlying entries drop out of Phase 2 and into a later, slower phase. If your reconciliation deadline is under 30 days away, CBP guidance says file the Type 09 first. Third, finally liquidated entries (more than 80 days past liquidation) are now covered by Phase 3 following a July 17, 2026 CIT order — but only for importers who have already filed their own CIT lawsuit; the government's Federal Circuit appeal of the broader refund order remains pending.
What is the False Claims Act risk in CAPE filings?
Every CAPE Declaration requires the importer to certify that all entry summaries comply with applicable law. If a customs broker misclassified goods and the importer certifies the claim, that constitutes a false claim under the False Claims Act. CBP uses AI and the DOJ-DHS Trade Fraud Task Force to audit filings. Large claims face heightened audit scrutiny. The Tariff Bureau’s Claim Audit & Optimization service reviews your entries before you certify.
Can foreign manufacturers recover IEEPA tariffs?
Foreign manufacturers selling under DDP (Delivered Duty Paid) terms may have absorbed IEEPA tariff costs into their pricing or margins. The Tariff Bureau advises DDP exporters from Vietnam, Taiwan, South Korea, India, Bangladesh, and Indonesia on IOR advisory, CAPE enrollment options, and rerouting analysis to reduce ongoing exposure.
Does Phase 2 cover my reconciliation entries automatically?
Not always. Entries filed before approximately May 31, 2025 that liquidated on the standard 314-day reconciliation cycle have already exceeded the 80-day window and fall outside Phase 2, regardless of reconciliation status. The Tariff Bureau was built to identify exactly which of your reconciliation entries are Phase 2-eligible versus which require a different track.
How does The Tariff Bureau charge for refund recovery?
The Tariff Bureau offers an IEEPA Eligibility Screening for $1,500 flat — a 4-qualifier written determination, including Phase 1/Phase 2 filing-sequence review, credited toward any full engagement. Full Recovery Package engagements start at $4,000 base plus 12–15% contingency on recovered amounts. Minimum $50,000 estimated recovery required for full engagements. View full pricing →
IEEPA Resource Library
IEEPA Tariff FAQ IEEPA Glossary IEEPA HTS Codes Protest vs. Refund CAPE Portal Deadlines CBP Refund Process Federal Circuit Appeal DDP Foreign Manufacturers For Importers & CFOs For Lenders Supply Chain Recovery Contingency Model China Imports Vietnam Imports Taiwan Imports South Korea Imports India Imports EU Imports Atlanta Importers

Phase 3 is open.
Filing status matters.

$86.3B has been repaid and $121.75B accepted across CAPE Phase 1, 2, and 3. The Tariff Bureau is taking intake today — including a filing-sequence and CIT-filing status check to protect your eligibility.

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