IEEPA Tariff Refund Glossary: Plain-English Definitions

CBP's online trade portal. The ACE Secure Data Portal is where all CAPE Declarations are submitted, where bank account (ACH) information is enrolled, and where importers and customs brokers manage entry filings. Access is required to file CAPE Declarations. Foreign importers of record without ACE accounts can authorize their U.S. licensed customs broker to file on their behalf.

The electronic funds transfer network used by the U.S. Treasury to disburse IEEPA refunds. CBP requires a U.S. bank account enrolled in ACE for ACH refund disbursement. Foreign bank accounts cannot receive ACH payments directly. As of June 29, 2026, 8,384 certified refunds are stuck at Treasury because the importer never enrolled ACH banking information in ACE.

CBP's automated IEEPA refund processing system within ACE. Importers or their licensed customs brokers upload a CSV CAPE Declaration listing entry numbers. ACE validates the file, removes IEEPA Chapter 99 HTS codes, reliquidates entries, and triggers Treasury ACH disbursement. CAPE operates in three phases: Phase 1 (active April 20, 2026), Phase 2 (active June 29, 2026), and Phase 3 (targeting late July 2026).

The CSV file submitted by the importer of record or authorized customs broker through ACE listing entry numbers for which IEEPA duty refunds are sought. Each Declaration is limited to 9,999 entries. Declarations cannot be amended once accepted — additional entries require a new Declaration. The CAPE Declaration template is available in the CAPE tab of the ACE Portal.

IEEPA tariffs were encoded on entry summaries under Harmonized Tariff Schedule Chapter 99 subheadings — specifically the 9903.01.xx and 9903.02.xx ranges, differentiated by country of origin at the eight-digit level. CAPE removes these codes during processing; the duty amount associated with them becomes the refund. Entries without a qualifying Chapter 99 code fail CAPE validation.

The U.S. Court of International Trade is the federal court with exclusive jurisdiction over customs and trade law matters. Following the Supreme Court's IEEPA ruling, CIT Judge Richard Eaton issued orders requiring CBP to refund IEEPA duties. DOJ appealed those orders to the Federal Circuit on June 2–3, 2026. Under DOJ's current position, only importers who filed individual Section 1581(i) lawsuits at the CIT qualify for Phase 3 refunds.

The official CBP form that documents an import shipment — listing the importer of record, HTS codes, declared value, duties paid, and liquidation status. The IOR named on Form 7501 is the party eligible to file a CAPE Declaration. Your licensed customs broker filed Form 7501 on your behalf and holds copies in their ACE account.

On June 2–3, 2026, DOJ appealed the CIT's universal IEEPA refund order to the U.S. Court of Appeals for the Federal Circuit. DOJ argues the order is an impermissible universal injunction under Trump v. CASA (2025). The appeal does not halt Phase 1 or Phase 2 CAPE processing. It directly threatens Phase 3 refunds for non-CIT-plaintiff importers with finally liquidated entries. No briefing schedule has been set as of July 10, 2026.

An entry whose liquidation is final — meaning it occurred more than 80 days before the CAPE Declaration filing date (90 days from CBP's perspective, with a 10-day buffer). Finally liquidated entries are excluded from CAPE Phase 1 and Phase 2. Phase 3 targets finally liquidated entries, but under DOJ's current position only for CIT plaintiffs. These entries cover approximately $11.4 billion, or 7% of total IEEPA tariff revenue per Cato Institute analysis.

CBP Form 4811 — Authorization for Refund of Excessive Duty Deposits. Allows an importer of record to designate a third party (such as The Tariff Bureau) to receive the IEEPA refund ACH payment directly from Treasury. Must be executed and on file with CBP before the CAPE Declaration is submitted. The designee's U.S. bank account must be enrolled in ACE. Commonly used by foreign IORs without U.S. bank accounts, or by importers using a contingency advisory firm.

The United States' official classification system for imported goods. Every imported product is assigned an 8-to-10-digit HTS code that determines its duty rate. IEEPA tariffs were encoded as additional HTS Chapter 99 codes on top of standard product classifications. Identifying the IEEPA Chapter 99 codes on your entry summaries is the first step in determining your refund exposure.

The federal statute (50 U.S.C. § 1701 et seq.) that the President invoked to impose tariffs in 2025. On February 20, 2026, the Supreme Court ruled 6–3 in Learning Resources v. Trump that IEEPA does not authorize the President to impose tariffs. The ruling made all IEEPA duties unlawfully collected — opening $166 billion in refunds across 330,000 importers.

The party named on CBP Form 7501 as responsible for the imported goods and for paying duties. Only the IOR or their licensed customs broker (under a valid Power of Attorney) can file a CAPE Declaration. The IOR is the party entitled to receive the IEEPA refund — not the buyer, seller, or freight forwarder unless they are also the IOR.

CBP's final determination of the duties and fees owed on an entry. Liquidation typically occurs within 314 days of entry, though it can happen much sooner. Unliquidated entries (not yet finally liquidated) are eligible for Phase 1. Entries within 80 days of liquidation are also Phase 1-eligible. Entries more than 80 days past liquidation are 'finally liquidated' and fall under Phase 3.

A legal authorization from the importer of record allowing a licensed customs broker to act on the IOR's behalf for customs purposes, including filing CAPE Declarations in ACE. The POA must be valid and on file before the broker can submit a CAPE Declaration on the IOR's behalf.

A special entry type used to finalize the duty liability on entries initially filed with estimated or incomplete information, such as prices subject to change. Phase 2 covers entry types 01, 02, and 06 that are flagged for reconciliation and for which the Type 09 has not yet been filed. Once the Type 09 is filed, the underlying entries drop out of Phase 2 eligibility. Filing sequence is critical: CAPE Declaration first, Type 09 second.

The 10% global import surcharge imposed under Section 122 of the Trade Act of 1974 on February 24, 2026 — after IEEPA tariffs were struck down. Section 122 expires July 24, 2026 by hard statutory limit (150 days maximum). Section 122 duties are entirely separate from IEEPA duties and are not refundable through CAPE. USTR has proposed Section 301 replacement duties at 12.5% on 46 countries.

Federal statute requiring CBP to pay interest on duty refunds paid late. Interest accrues from the date duties were paid through the date of refund disbursement. Industry-wide IEEPA interest accrual is estimated at approximately $650 million per month. Interest is included in the consolidated ACH refund payment alongside principal duty recovery.

The Tariff Bureau's proprietary AI-powered platform for IEEPA tariff refund eligibility analysis. TariffIQ™ screens entry history against CAPE phase criteria, validates HTS codes, models refund and interest amounts, identifies filing sequence risks, and generates ready-to-file CAPE Declaration CSV packages. Alex Monroe is The Tariff Bureau's AI trade analyst persona powered by TariffIQ™, available 24/7 at tariffbureau.com.

See Reconciliation Entry above. The entry type filed to finalize duty liability for entries initially flagged for reconciliation. Filing a Type 09 before a CAPE Declaration permanently excludes the underlying Phase 2-eligible entries from Phase 2 processing. Timing of the Type 09 relative to the CAPE Declaration is the most common Phase 2 filing error.

The legal concept at the center of the Federal Circuit appeal. The CIT's March–April 2026 orders directed CBP to refund IEEPA duties to all importers of record — not just those who had filed lawsuits. DOJ argues this constitutes an impermissible 'universal injunction' under the Supreme Court's 2025 ruling in Trump v. CASA. Whether the Federal Circuit agrees will determine whether Phase 3 refunds flow to non-CIT-plaintiff importers.