IEEPA Tariff Refund Recovery
Federal courts ordered billions in IEEPA duty refunds for U.S. importers. CBP's CAPE system is processing claims now. Here's what you need to know — and how to file.
The International Emergency Economic Powers Act (IEEPA) authorized a series of executive orders in 2025 imposing additional tariff duties on goods imported from dozens of countries. U.S. district courts subsequently held that certain of these duties were unlawfully imposed under IEEPA's scope and ordered CBP to refund the excess duties paid by importers of record.
CBP developed the Customs Automated Processing Engine (CAPE) to administer these court-ordered refunds. As of September 11, 2026, $134.7 billion in claims have been accepted and $122 billion disbursed across more than 27 million processed entries. If your company imported goods from a covered country between 2025 and 2026 and has not yet filed, your refund window is still open — but it is not unlimited.
Phase 3 Alert — October 6, 2026: CBP is opening CAPE eligibility to finally liquidated entries on October 6. If your entries are in finally liquidated status, you cannot file under Phase 1 or 2 — you must wait for Phase 3. Start your assessment now so you are ready to file on day one.
| Phase | Entry Type | Status | Notes |
|---|---|---|---|
| Phase 1 | Liquidated entries (standard) | OPEN | Post Summary Corrections accepted. Most importers file here. |
| Phase 2 | Liquidated entries (extended) | OPEN | Covers entries where liquidation was delayed or protested. |
| Phase 3 | Finally liquidated entries | OPENS OCT 6 | Separate filing pathway. Launches October 6, 2026. High-volume importers with multi-year contracts may have significant Phase 3 exposure. |
The refund-eligible IEEPA duties apply to goods with origin in countries subject to the settled tariff rates under Annex I of EO July 31, 2025, effective August 7, 2025. The settled rates by country:
| Country / Region | IEEPA Settled Rate | Notes |
|---|---|---|
| Vietnam | 20% | High-volume electronics, apparel, footwear |
| Taiwan | 20% | Semiconductors, machinery, electronics |
| South Korea | 15% | Vehicles, steel, electronics |
| Japan | 15% | Automotive parts, machinery, chemicals |
| India | 25% | Pharmaceuticals, textiles, IT equipment |
| European Union | 15% total | Blended rate across member states; machinery, chemicals, food products |
| China | ~30% blended | Overlaps with Section 301 duties — eligibility requires careful entry-level analysis |
Country of origin is determined by CBP's substantial transformation test — not the country of shipment or purchase. Goods assembled from multi-country components require origin analysis before filing. See Country of Origin Rules for a full breakdown.
Refund claims are filed through CBP's CAPE system, typically via a Post Summary Correction (PSC) for each eligible entry. The process requires:
Common filing errors that cause claim reductions or rejections: HTS misclassification at the Chapter 99 level; origin documentation gaps for goods with multi-country supply chains; filing under the wrong CAPE phase for the entry's liquidation status; missing or inconsistent commercial invoices on the original entry summary.
Importers with a small number of straightforward entries and clear origin documentation can sometimes file independently through their licensed customs broker. Most importers, however, benefit from a specialist for several reasons:
Companies with hundreds or thousands of entries need systematic entry review and bulk processing — not a manual entry-by-entry approach that misses eligible claims.
Multi-country sourcing, FTZ processing, or transshipment through a third country all create origin complexity that requires expert analysis before filing.
Finally liquidated entries have a distinct filing pathway opening October 6. Importers with large Phase 3 exposure need to be ready to file immediately on launch.
CF-28 information requests and CF-29 action notices require precise, documented responses. Errors at this stage can permanently reduce your recovery.
The Tariff Bureau handles IEEPA refund recovery on a contingency fee basis — no upfront cost, no fee unless your refund is recovered. A free assessment establishes your estimated refund exposure before any engagement begins.
U.S. importers of record who paid additional duties under IEEPA executive orders on goods with origin in a covered country — including Vietnam, Taiwan, South Korea, Japan, India, and EU member states — and whose entries are liquidated (Phases 1 and 2) or finally liquidated (Phase 3, launching October 6, 2026) are potentially eligible.
As of September 11, 2026, CBP has accepted $134.7 billion in refund claims and disbursed $122 billion across 27.2 million processed entries. Phase 3 — covering finally liquidated entries — launches October 6, 2026.
CAPE (Customs Automated Processing Engine) is CBP's automated system for processing court-ordered IEEPA tariff refunds. Importers file Post Summary Corrections or direct CAPE submissions for eligible entries. CBP reviews and issues refunds by Electronic Funds Transfer or check.
CBP has established processing windows by entry liquidation status. Importers must file before the applicable window closes for their entry phase. Phase 3 opens October 6, 2026 — acting early reduces risk of missing the window as CBP processing volumes increase.
Importers with large portfolios, complex supply chains, or multi-country sourcing benefit significantly from a specialist. Filing errors — particularly HTS misclassification and origin documentation gaps — are the primary reasons CBP reduces or rejects claims.
The Tariff Bureau's free assessment tells you your estimated IEEPA refund exposure — before you commit to anything. Contingency fee only. No recovery, no fee.
Get Free AssessmentU.S. importers paid billions in IEEPA tariffs that a federal court has ordered refunded. Time-sensitive — act before CBP processing windows close.
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