IEEPA Tariff Refund Recovery

IEEPA Tariff Refund FAQ: Your Questions Answered

Everything importers ask about IEEPA refund recovery — eligibility, process, timeline, fees, and what the federal court orders mean for you.

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Frequently Asked Questions

What is an IEEPA tariff?

IEEPA stands for the International Emergency Economic Powers Act. The executive branch used IEEPA authority to impose emergency tariffs on imports from over 50 countries beginning in 2025. These tariffs were imposed by executive order rather than through the normal Congressional trade process.

Why are IEEPA tariffs being refunded?

The U.S. Court of International Trade issued an injunction finding that the executive branch exceeded its statutory authority under IEEPA when imposing these tariffs. The court ordered CBP to refund all unlawfully collected IEEPA duties. The DOJ has appealed, but the refund obligation has not been stayed.

How do I know if I qualify?

Qualification requires that you were the importer of record on entries where IEEPA duties were collected, and that those entries involved goods classified under IEEPA-affected HTS codes from affected countries of origin. Use our free assessment tool to check your specific situation.

How much can I recover?

Recovery amounts depend on your total dutiable value, the applicable IEEPA rate, and the number of qualifying entries. Commercial importers typically recover between $50,000 and several million dollars. Use our TariffIQ™ platform for an estimate specific to your import history.

What does contingency fee mean?

Contingency fee means The Tariff Bureau earns a percentage of what we actually recover. If we don't recover anything, you owe nothing. There is no retainer, no hourly billing, and no upfront cost of any kind.

How long does the process take?

CBP is targeting 60–90 day processing timelines for complete, properly filed claims. From engagement to cash receipt, most importers should expect 90–120 days for straightforward claims.

What is the CAPE portal?

CAPE stands for CBP's Automated Processing Environment. It is the official electronic portal for IEEPA refund claim submissions. CBP opened the CAPE portal on April 20, 2026.

What happens if the DOJ appeal succeeds?

If the Federal Circuit reverses the CIT injunction, CBP would no longer be required to process new refund claims. However, claims that have already been filed and are in the processing queue may receive different treatment depending on the appellate court's specific ruling. Filing now — before any adverse appellate decision — is the dominant strategy.

Can foreign manufacturers recover IEEPA duties?

The refund right belongs to the U.S. importer of record. Foreign DDP manufacturers may have contractual recovery rights against the U.S. buyer or through the customs broker chain, but they do not have a direct CBP claim unless they were listed as the importer of record.

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