Do Your Entries Qualify for an IEEPA Refund?

Reconciliation-flagged entries with no Type 09 on file are exactly what CAPE Phase 2 (live since June 29, 2026) was built for — roughly 2.8 million entries and $28.7 billion in potential refunds. One trap: file your CAPE Declaration before your Type 09 reconciliation entry, or those entries drop out of Phase 2 into a later, slower phase. If your reconciliation deadline is under 30 days away, CBP guidance says file the Type 09 first. Start now — refunds are actively flowing, with $71.06 billion already certified to Treasury.

Unliquidated entries — or entries liquidated within roughly 80 days — are what CAPE Phase 1 has been processing since April 20, 2026. Refunds are actively flowing: per CBP’s July 1 court filing, $71.06 billion has been certified and sent to Treasury, and interest accrues on your refund under 19 U.S.C. § 1505 until it’s paid. Clean filings process fastest — roughly 30% of submissions get rejected for fixable errors like HTS coding and CSV formatting.

Entries liquidated more than ~80 days ago fall outside CAPE Phase 1 and Phase 2. CBP’s current position is that finally liquidated entries require an individual case at the Court of International Trade — and CAPE Phase 3 (targeted for late July 2026) is expected to cover only importers who have filed suit. The government’s pending appeal makes this the most time-sensitive category. A protest under 19 U.S.C. §1514 may also be available if you’re within 180 days of liquidation. We prepare the documentation and coordinate with trade counsel.

Per CBP, entries with a reconciliation already on file will be included in a future phase of CAPE — they’re deferred, not lost. Meanwhile, most importers hold a mix: other entries may qualify under Phase 1 or Phase 2 right now, and any finally liquidated entries need CIT-track attention before Phase 3. A full assessment maps every entry to its correct track so nothing waits longer than it has to.

If you sold Delivered Duty Paid and absorbed IEEPA tariffs into your pricing, the refund is paid to the Importer of Record on the entries — often your U.S. subsidiary, logistics provider, or customer. The Tariff Bureau advises DDP exporters on identifying the IOR, CBP Form 4811 designation, ACE registration, and recovery coordination. This is a genuine recovery path — it just needs the right structure.

Section 301, Section 232, and Section 122 duties are not refundable through CAPE. But the Section 122 global tariff was ruled unlawful by the CIT on May 7, 2026 (relief limited to the plaintiff importers; stayed on appeal) — documenting those payments and calendaring protest deadlines now preserves your options if the ruling holds. And the post-IEEPA tariff architecture (new Section 301 investigations targeting 16 trading partners) means classification and exposure monitoring matter more than ever.

Most importers don’t know their liquidation dates or reconciliation status off-hand — that data lives in your ACE portal and broker records. Our free assessment walks through it with you and maps every entry to its correct track: Phase 1, Phase 2, protest, or CIT. With $71.06 billion already certified to Treasury and interest accruing on unpaid refunds, finding out is worth ten minutes.