IEEPA Tariff Refunds: Who Can Claim, and How to File Through CAPE
By Archit Mathur · Published · Last updated
Short answer
The Supreme Court struck down the IEEPA tariffs on 20 February 2026. As of 11 September, CBP had accepted $134.7 billion in refunds through CAPE and sent $122 billion, with interest, to Treasury. If you were the importer of record, you claim by uploading a CSV of entry numbers as a CAPE Declaration in the ACE Portal.
There is a thread on the FBA subreddit titled, flatly, that the government owes a lot of you money and most of you do not know it. Underneath it, the highest-voted reply is a question: you say the deadline is real, but what is the deadline? Nobody answered. Four months later the question still stands, because the answer runs on three separate clocks.
The answer below comes from the court orders and CBP's own filing instructions, and it was written on 29 September 2026. None of it is legal advice, and eligibility on a specific entry is a question for a customs broker or a trade attorney. But the shape of the thing is knowable, and knowing the shape is what tells you whether to bother.
Correction
Corrected 29 September 2026: this page said CAPE Phase 3 had no date, and gave figures as of 21 August, including an outstanding balance. Phase 3 opens on 6 October 2026 for plaintiffs, and the figures below are as of 11 September. The balance was our own subtraction of refunds that include interest from duties that do not, so it has been removed.
What the Supreme Court decided, and when
On 20 February 2026, the Supreme Court held that the tariffs imposed under the International Emergency Economic Powers Act were unlawful, in Learning Resources, Inc. v. Trump (opens in a new tab). February is when the legal question was settled; April is when CBP stood up the machinery for paying the money back.
The Court of International Trade then had to decide what that meant operationally. On 4 March it ordered CBP to refund IEEPA duties. On 20 March it amended the order and urged importers to protect entries liquidated within the previous 180 days. On 27 March it amended the order again, and that third amendment is the one that matters most to a small importer.
The sentence the whole case turns on
The amended order in Atmus Filtration, Inc. v. United States (opens in a new tab) directs that "any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties." Before 27 March, finality was a wall. After it, it was not. If you concluded months ago that you had missed this, that conclusion was drawn against a rule that has since changed.
Do you qualify? The importer-of-record test
This is the question that decides everything else, and it has nothing to do with selling on Amazon. CBP refunds the importer of record. The importer of record is whoever was legally responsible for the entry and paid the duty, named in block 30 of the Entry Summary (opens in a new tab).
If you bring containers in under your own IOR number, work with a customs broker who files 7501s in your name, and pay duty out of your own account, you are the importer of record and this applies to you directly.
If you buy DDP, delivered duty paid, from a supplier who quotes you a landed price and handles customs at their end, you are almost certainly not. Your supplier or their forwarding agent was the importer of record, they paid the IEEPA duties, and the refund follows them. You paid the tariff economically, inside the price you were quoted, but CBP issues refunds (opens in a new tab) to the importer of record, or to a notify party the importer designated on CBP Form 4811. Whether you can recover anything from your supplier is a question for your broker or counsel.
This is an uncomfortable answer for a lot of private-label sellers, and it is the reason the outstanding balance skews the way it does. The importers who structured their own customs clearance are exactly the ones sophisticated enough to have claimed already.
Commingled FBA inventory does not affect eligibility
A recurring worry on the forums is that commingled FBA inventory complicates eligibility, because you can no longer point to the specific units. It does not. The refund attaches to the customs entry, not to the inventory, and the entry closed the moment the goods cleared. What happened to the units afterwards, whether sold, commingled, removed or written off, is irrelevant to whether the duty on that entry was lawfully collected.
What has been refunded so far
The numbers come from declarations filed with the Court of International Trade by CBP, and they are unusually specific for something this size. The first set of headline totals was reported on 5 August (opens in a new tab), and CBP filed further updates on 25 August and 15 September. The table uses the 15 September declaration, with figures as of 11 September, as GHY International reported it (opens in a new tab). These move roughly fortnightly, so check the date on any figure you see quoted elsewhere, including ours.
| Figure | Amount | As of |
|---|---|---|
| Collected under IEEPA | $166 billion, from 330,000+ importers | Feb 2025 - Feb 2026 |
| Entries in declarations that passed file validation | 27.2 million entries | 11 September 2026 |
| Potential and certified refunds accepted through CAPE | about $134.7 billion | 11 September 2026 |
| Certified and sent to Treasury, including interest | about $122 billion | 11 September 2026 |
| Held back for missing bank details | about $1.3 billion, across 20,184 refunds | 11 September 2026 |
Refunds so far have gone disproportionately to large importers with compliance departments. That is a staffing difference: a company with a trade team filed in April, and a company where the founder also does the sourcing did not.
How to file: a CSV, in the ACE Portal
The mechanism is called a CAPE Declaration, for Consolidated Administration and Processing of Entries, and CBP built it inside the Automated Commercial Environment specifically so that refunds could be consolidated rather than fought entry by entry.
Three things have to be true before you can file. You or your broker need an active ACE Secure Data Portal account. Your bank details need to be on that account, which means enrolling in ACH refunds. And you need the list of entry numbers.
The filing itself is smaller than people expect. A CAPE Declaration (opens in a new tab) is a CSV file containing a list of entries and, in CBP's own words, no other information is required. The template comes from the Upload button on the CAPE tab. One declaration holds up to 9,999 entries, and you can file more than one. It is not submitted through the Automated Broker Interface, which trips up brokers expecting the usual channel. CBP publishes a guide to building the declaration and to what each error message means (opens in a new tab).
Only two parties may file: the importer of record on those entries, or the customs broker who filed them on the importer's behalf. A third party who did not touch the original entry cannot submit for you.
Where the entry number lives
On the CBP Form 7501 Entry Summary, it is block 1, the top-left field, labelled Filer Code/Entry Number. If you have never handled a 7501, your broker has a copy of every one filed for you and can export the list. Once your ACE Portal account is live the entries are visible there too.
The deadline question, answered properly
There is no single deadline, which is why nobody gave that Reddit thread a straight answer. There are three clocks and they run on different entries.
| Entry status | What governs it | Practical position |
|---|---|---|
| Not yet liquidated | Stays open until liquidation, customarily around 314 days after entry | The cleanest case. CAPE Phase 1 covers these. |
| Recently liquidated | 180-day protest window under 19 U.S.C. 1514 | CAPE Phase 1 also covers certain entries within 80 days of liquidation. |
| Liquidation final | CIT amended order of 27 March 2026 | Directed to be reliquidated without regard to IEEPA duties. |
CBP is building CAPE in phases, and the phases matter because they determine what the system will accept today rather than what the court has authorised in principle. Phase 1 covers certain unliquidated entries and certain entries within 80 days of liquidation. Phase 2 extends to entries flagged for reconciliation where the reconciliation entry is not yet on file. More complicated scenarios are explicitly deferred to later phases.
Phase 3 was expected in August, was delayed (opens in a new tab) while CBP built additional system validations, and opens on 6 October 2026 (opens in a new tab). Its scope is narrow. The court's order of 27 August describes "CAPE Phase III, which covers finally liquidated entries filed by plaintiffs in lawsuits, for which reliquidation has been ordered by the court" (opens in a new tab). Plaintiffs who gave CBP a valid importer-of-record number by 30 July 2026 can file from 6 October, and CBP says it will give the others additional instructions. Phases 1 and 2 remain operational.
Phase 3 is not the latecomers' phase
It is tempting to read Phase 3 as the one that eventually picks up everyone whose entries already liquidated. That is not what it says. The phrase "filed by plaintiffs" is the scope of the phase, and it points the other way: it covers entries belonging to parties who had already brought their own action. The government's position in the appeal, set out below, is precisely that non-party importers with finalised entries cannot rely on a blanket order and must initiate their own case. If your entries are liquidated and you are not a plaintiff, take the question to a customs lawyer rather than waiting for Phase 3. The answer gets worse the longer it is left.
One exclusion applies across CAPE rather than only to Phase 3, so check it before you build a CSV. CBP's entry validation rules (opens in a new tab) reject certain entry types outright: temporary importation under bond (23), duty deferral (08), reconciliation (09) and drawback (047). If your entries are any of those, they will not pass validation in any current phase, not merely in Phase 3.
$1.3 billion held for missing bank details
As of 11 September, 20,184 approved refunds worth about $1.3 billion had not been sent to Treasury because the importer of record or its authorised CBP Form 4811 designee had not provided ACH account information (opens in a new tab). The money is calculated and waiting, and the banking information has to be supplied through the ACE Portal. If you filed and have heard nothing, check your ACH enrolment before you assume you are in a queue. You may simply have no account for the payment to land in.
The honest summary is this: the legal entitlement is currently broad, the filing system is catching up to it, and the thing that will actually cost you money is assuming a closed entry is a dead entry. But "currently" is doing real work in that sentence. The government has appealed to the Federal Circuit (opens in a new tab), arguing that the CIT exceeded its authority by extending relief to importers who never filed suit, and leaning on the 2025 Supreme Court decision restricting universal injunctions. If that appeal succeeds, the broad entitlement narrows toward parties who actually sued. That is an argument for filing now rather than waiting to see how it lands. Separately, the ordinary protest route under section 514 remains available: 180 days from liquidation (opens in a new tab), filed on CBP Form 19 or any signed document that can be construed as contesting the decision, through the ACE Protest module or on paper at the port of entry.
Do not pay someone ten per cent to upload a CSV
CBP's own page on this carries a banner reading, in effect, do not get scammed: file your IEEPA refund with a CAPE Declaration in ACE. That banner exists because a contingency-fee industry appeared within weeks of the ruling, and a seller who has actually been paid described the offer he turned down: ten per cent of the recovery, to do a job he then did himself in an afternoon.
The judgement call is arithmetic. If you have four entries a year and a broker who already holds your 7501s, the work is finding the numbers and uploading a file. If you have several thousand entries across multiple IOR numbers, reconciliation is real work and paying for it is reasonable. Ten per cent of a six-figure refund for a CSV upload is not.
What happens after you file, and what does not
Once a declaration is validated and accepted, ACE strips the IEEPA Chapter 99 provision and the corresponding duties from the affected entry summary lines, producing an updated entry. CBP then reviews, liquidates or reliquidates, and consolidates refunds by importer of record and liquidation date. If you have designated someone else to receive refunds on your behalf via CBP Form 4811, they are consolidated to that party instead.
CBP says valid refunds are generally issued within 60 to 90 days of acceptance, unless a compliance concern requires further review. Entries that are extended, suspended, under review, or filed as warehouse entries keep their liquidation status and pay out at liquidation rather than on that timetable.
Two things that can reduce the number
Refunds are subject to the netting of all over- and under-payments across the entire entry at liquidation, under 19 C.F.R. § 159.1. They can also be diverted to offset legally fixed and undisputed debts you owe the United States, under 19 C.F.R. § 24.72. Neither is common for a small importer in good standing, and both are better to know about before the deposit lands short.
The part sellers find hardest is that there is no arrival notice. The money simply appears. The seller who reported a $55,000 refund landing described it turning up roughly a week after he applied, with no confirmation in between, and others in the same thread described being paid in instalments: a partial payment, then a sub-$2 payment, then most of the balance. ACE does have reports for tracking it. CBP's CAPE notice (opens in a new tab) lists ES-022, which "links accepted CAPE declarations, entries, and refund numbers", and REV-603 and REV-615, which follow declarations once they reach Treasury. Run them against your entry list instead of waiting for a deposit to tell you.
The pattern this is an instance of
Take away the customs law and this is money you are owed, through a process nobody announced to you, with no notification when the entitlement arose, when the filing route opened, or when the money arrived.
Ask your broker for the list of entry numbers this week, and check your ACH enrolment while you are there.
Frequently asked questions
Do Amazon FBA sellers qualify for an IEEPA tariff refund?
Only if you were the importer of record on the entry. If you imported under your own IOR number and paid the IEEPA duties, you are the party CBP refunds. If you bought DDP from a supplier who handled customs, the supplier or their agent was the importer of record and the refund follows them, not you.
What is the deadline to claim an IEEPA tariff refund?
There is no single date. Unliquidated entries stay open until they liquidate, which is typically around 314 days after entry. Once an entry liquidates, the statutory protest window is 180 days under 19 U.S.C. 1514. The Court of International Trade amended its order on 27 March 2026 to cover entries whose liquidation is already final, which widened eligibility considerably.
How do I find my CBP entry number?
It is block 1 of the CBP Form 7501 Entry Summary, the top-left field, labelled Filer Code/Entry Number. Your customs broker holds a copy of every 7501 filed on your behalf. Entry numbers are also visible in your ACE Portal account once it is active.
Do I need a customs broker to file a CAPE claim?
No. CBP allows the importer of record to file a CAPE Declaration directly through the ACE Secure Data Portal. The submission is a CSV file containing a list of entry numbers and nothing else. Brokers can file on your behalf if they filed the original entries, but the process does not require one.
How long does a tariff refund take to arrive?
CBP states that valid refunds are generally issued 60 to 90 days after a CAPE Declaration is accepted, unless a compliance concern requires further review. Entries that are extended, suspended, under review, or filed as warehouse entries keep their existing liquidation status and are refunded at liquidation instead.
What if my entries already liquidated?
You may still be eligible. The CIT order of 27 March 2026 directs CBP to reliquidate entries without regard to the IEEPA duties even where liquidation is final. That is the single most important sentence in the whole case for a small importer, because most small importers only discovered the refund after their entries had closed.
Sources
- 01Learning Resources, Inc. v. Trump, No. 24-1287 (20 February 2026) (opens in a new tab) — Supreme Court of the United States
- 02Amended order of 27 March 2026, Atmus Filtration v. United States (Ct. No. 26-01259, ECF 50) (opens in a new tab) — U.S. Court of International Trade, via CourtListener
- 03International Emergency Economic Powers Act (IEEPA) Duty Refunds (opens in a new tab) — U.S. Customs and Border Protection
- 04ACE Portal: CAPE Declarations and Error Definitions (opens in a new tab) — U.S. Customs and Border Protection
- 05CBP Form 7501: Entry Summary (opens in a new tab) — U.S. Customs and Border Protection
- 0619 U.S. Code 1514 - Protest against decisions of Customs Service (opens in a new tab) — Cornell Legal Information Institute
- 07CBP IEEPA Refund Update: $132.5 Billion Accepted for CAPE Processing as Phase 3 Is Delayed (opens in a new tab) — J.M. Rodgers Co., reporting CBP's 25 August 2026 update to the CIT
- 08US Government Challenges Universal Tariff Refunds: What Importers Need to Know (opens in a new tab) — Liang + Mooney, PLLC, 12 August 2026
- 09
- 10CBP Launches CAPE for IEEPA Duty Refunds (opens in a new tab) — GHY International, reporting CBP's 15 September 2026 declaration to the CIT
- 11Order of 27 August 2026, Freestyle World, Inc. v. U.S. Customs and Border Protection (Ct. No. 26-01088, ECF 40) (opens in a new tab) — U.S. Court of International Trade, via CourtListener
- 12Consolidated Administration and Processing of Entries (CAPE), last updated 10 July 2026 (opens in a new tab) — U.S. Customs and Border Protection
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