Direct Answer
Yes. Small businesses that imported goods between March 2025 and February 24, 2026 and paid IEEPA tariffs are eligible for refunds through CBP's CAPE system — the same as large importers. However, Cato Institute data shows most refunds paid so far have gone to large firms. Small importers need to act now to avoid being left at the back of the queue.
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 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.
IEEPA Tariff Refunds for Small Businesses
Can small businesses get IEEPA tariff refunds?
Step 1
Why Small Importers Are Being Left Behind
As of June 29, 2026, CBP has approved refunds covering approximately 60% of its total refund obligation — but that amount represents only 30% of all import entries on which IEEPA tariffs were paid. In other words, the refunds are concentrated in large, high-value entries from large importers. CIT Judge Richard Eaton noted at the June 9 hearing that most refunds processed so far have gone to large firms. Small importers with lower per-entry values end up further back in the processing queue.
Step 2
Your Rights Are the Same
The CAPE system has no minimum refund amount and no preference for large importers. Your legal entitlement to a refund — established by the Supreme Court's ruling in Learning Resources v. Trump — is identical to Walmart's, Ford's, or any other importer's. The difference is not legal status, it is filing speed, preparation quality, and queue position. Filing earlier with a clean, pre-validated CAPE Declaration moves you up the queue.
Step 3
What Small Importers Need to File
You need the same four things as any other importer: an active ACE account (or a licensed customs broker with ACE access who filed your entries), a U.S. bank account enrolled for ACH in ACE, your entry summary numbers from Form 7501, and confirmation that your entries have qualifying IEEPA Chapter 99 HTS codes. If you worked with a customs broker, contact them immediately — they have all of this information.
Step 4
Why CAPE Phase 3 Is More Urgent for Small Businesses
Small importers are statistically more likely to have finally liquidated entries — goods that cleared customs in 2025 and have already gone through CBP's standard 314-day liquidation cycle. Under DOJ's current position, those finally liquidated entries require an individual CIT lawsuit to qualify for Phase 3 refunds. The CIT's two-year statute of limitations begins expiring in early 2027 for the earliest IEEPA entries. Small businesses with finally liquidated entries face the tightest timeline.
Step 5
How Contingency Advisory Levels the Playing Field
Large importers have in-house trade compliance teams and dedicated customs counsel. Small importers typically don't. Contingency advisory firms like The Tariff Bureau level the playing field: no upfront fees, no retainers, no hourly rates. You pay nothing unless your refund is recovered. This makes professional CAPE preparation accessible to small importers who cannot afford $250–600/hour trade counsel.
Common Questions
Frequently Asked Questions
What is the minimum import volume to qualify for an IEEPA refund?
There is no minimum. Any importer of record who paid IEEPA duties on eligible entries is entitled to a refund. Even a single import shipment creates a refund claim if the entry is CAPE-eligible.
Do I need a lawyer to file for an IEEPA refund through CAPE?
No. CAPE Phase 1 and Phase 2 filings do not require an attorney. You need your licensed customs broker to submit the CAPE Declaration in ACE. An attorney is needed only if you are considering filing an individual CIT lawsuit for Phase 3 finally liquidated entry refunds.
How does The Tariff Bureau serve small importers?
The Tariff Bureau serves importers of all sizes on a contingency basis — no recovery, no fee. We perform eligibility screening, HTS code validation, CAPE Declaration preparation, and coordination with your licensed broker. For small importers, we offer a free assessment at tariffbureau.com/assessment to determine if your refund is large enough to be worth pursuing.
What if I cannot find my entry summaries?
Contact the customs broker who filed your entries — they maintain copies of all entry summaries in their ACE account and can pull your full import history from the duty period. If you used multiple brokers, contact each one for their portion of your entry history.
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Note: The Tariff Bureau's free assessment is available to importers of all sizes at tariffbureau.com/assessment. We will tell you candidly if your refund exposure is too small to make engagement worthwhile — we only take on contingency relationships where recovery is realistic.
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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.