IEEPA FAQ: Tariff refund rules, eligibility and filing steps

What’s the difference between liquidated and unliquidated entries? 

The distinction between liquidated and unliquidated entries is now central to refund strategy.

Unliquidated entries are still open within CBP’s system, allowing duties to be corrected before finalization. Under the CIT’s direction, these entries should be liquidated without IEEPA tariffs, meaning importers may receive refunds through standard CBP processing. However, in practice, refunds may require submission of CAPE declarations through the importer’s ACE account to trigger the refund.

Liquidated entries, by contrast, are considered final and can’t be adjusted through standard liquidation procedures. As a result, recovering duties on those entries requires additional steps, such as filing protests or participating in additional phases of CAPE that haven’t been clearly defined yet.

What's new with the IEEPA refund filing process?

The IEEPA refund process has shifted from a developing possibility to an active administrative filing process.

CBP launched the CAPE (Consolidated Administration and Processing of Entries) portal on April 20, 2026, establishing a defined mechanism for importers to pursue refunds. Refund requests are now submitted through the ACE Secure Data Portal using CAPE declarations in CSV format.

As of May 26, 2026, CBP reported receiving approximately 157,402 CAPE declarations. Roughly 70% passed initial file validation requirements, with approximately 15.9 million entries passing entry validation. CBP also reported approximately $85 billion in accepted refund claims and approximately $20.6 billion already processed through the CAPE refund component.

CBP is implementing the process in phases based on entry type and liquidation status, with the agency recalculating duties and issuing refunds directly through the system. As a result, importers now have a formalized pathway to seek recovery of IEEPA tariffs through CBP-administered procedures.

What are replacement tariffs and why do they matter?

With IEEPA no longer available as a tariff authority, policymakers are turning to other trade remedy tools. This includes tariffs introduced under Section 122, which provide temporary authority and are subject to a defined timeline. Current Section 122 tariffs are limited to a 150-day window and are set to expire on July 24, 2026, and cannot be immediately reimposed under the same provision.

On May 7th, 2026, the Court of International Trade (CIT) ruled 2-1 that the 10% surcharge tariffs under Section 122 are unlawful. However, unlike the IEEPA ruling, which made refunds available to all impacted importers, the CIT’s decision granted relief only to the plaintiffs involved in the case. The Trump Administration has already appealed the decision, and further litigation is expected before a final outcome is determined.

At the same time, additional trade remedy actions under Section 301 and Section 232 are developing and expected. These replacement tariffs could create new compliance requirements and shift future duty exposure, making it important for importers to stay adaptable as the policy landscape evolves.

What tariffs are refundable?

Tariffs that may be eligible for refund generally include duties paid under IEEPA that were later determined to be unlawful, as well as overpayments resulting from the incorrect application of tariff provisions.

It is equally important to understand what is not refundable in this context. This typically includes tariffs lawfully imposed under other authorities, such as:

• Section 301 tariffs for China-related trade remedies
• Section 232 tariffs on steel and aluminum
• Antidumping (AD) and countervailing duties (CVD)
• Other non-IEEPA trade remedies or statutory duties

These categories are generally not impacted by the IEEPA ruling and are not eligible for refund through the CBP CAPE process tied to IEEPA recovery.

Additionally, even within IEEPA-related entries, certain scenarios such as duty drawback, reconciliation filings or overlapping duty programs may require separate analysis and may not follow a straightforward refund path.

Are IEEPA tariffs automatically refundable?

IEEPA tariffs aren’t universally or immediately refundable, and treatment varies depending on entry status and entry type. Certain entry types, such as warehouse entries and warehouse withdrawals, are currently included in early phases of the CBP CAPE process, while others, including reconciliation entries, drawback claims, protested entries and AD/CVD entries, aren’t yet supported.

For unliquidated entries, the CIT ruling effectively allows CBP to remove IEEPA duties during liquidation, which may result in refunds being issued through standard CBP processing. In practice, this may still require CAPE submissions, and importers must be set up for ACH with CBP to receive refund payments.

For liquidated entries, the refund process for additional phases of CAPE hasn’t been clearly defined by CBP yet, however, importers may have to pursue recovery through formal administrative procedures, supported by documentation and subject to CBP review.

In both cases, preparation and data accuracy remain critical.

What’s the ACE portal for U.S. Customs compliance?

The ACE portal is CBP’s primary system for managing import data and compliance activities. It allows importers to access entry records, monitor liquidation status and generate reports that are essential for identifying refund opportunities.

Why is ACE critical for tariff refunds?

ACE is required to pursue and receive IEEPA tariff refunds. Importers can’t access the CBP CAPE process without an ACE account, and refunds can’t be issued by CBP without both ACE access and ACH enrollment for electronic payment.

Beyond access, ACE provides the data needed to distinguish between liquidated and unliquidated entries, calculate duties and validate claims. It also allows importers to monitor liquidation events, which is important given the CIT’s directive affecting unliquidated entries.

ACE access and ACH enrollment have become increasingly important as CAPE refunds are now being processed. CBP has reported that some approved refunds remain pending because ACH information was not available for the importer of record or authorized designee.

Why is ACH enrollment important for receiving an IEEPA refund?

CBP currently issues IEEPA refunds electronically. As a result, importers must have both an ACE account and ACH refund enrollment established before refunds can be received.

CBP has reported that some approved refunds remain pending because ACH information was not available for the importer of record or authorized designee.

Organizations that have not established ACH refund capability should do so as early as possible to avoid delays in receiving approved refund payments.

How to register for the CBP ACE portal?

Registering for the CBP ACE portal is a foundational step for managing compliance and preparing for any potential tariff refund activity.

While the process is relatively straightforward, it does require coordination with CBP systems and, in some cases, your customs broker.

The first step is ensuring that your company has a CBP Form 5106 (Importer Identity Form) on file. This form establishes or updates your importer profile with the CBP.

If your company has been importing goods, a version of this form is likely already on file, but it’s worth confirming that the information, particularly contact details, is current. If updates are needed, they can be submitted through your broker or directly following CBP instructions.

Once your importer record is established, you can apply for access to the ACE Secure Data Portal. This is done through the CBP ACE login page, where you will select the option to create a new account as an importer.

The application requires basic company information, identification details and user credentials. CBP provides step-by-step instructions within the application. Most applicants find the process manageable if they have their company information readily available.

After submitting the application, CBP will review the request and provision your account. Approval isn’t immediate. Due to volume and internal validation steps, it typically takes four to six weeks to receive access. Given the current surge in interest tied to IEEPA tariff refunds, delays are possible, so early registration is strongly recommended.

Once your account is approved, you can log in to the ACE portal and verify that your company is correctly configured as an importer. This step is more important than it may seem. Users should confirm that the account reflects the correct importer of record, that access permissions are appropriate, and that key features, such as reporting capabilities, are available. If anything appears incorrect, it may require follow-up with the ACE help desk to resolve.

Finally, take the extra step of configuring your account for practical use. This includes setting up contact information, assigning additional users if needed and critically enabling ACH refund functionality.

Without ACH setup, CBP may not be able to disburse refunds even after claims are approved. Taking the time to complete these configurations upfront can prevent delays later when refund processes are fully implemented.

What is CAPE?

CAPE (Consolidated Administration and Processing of Entries) is CBP’s system for processing IEEPA tariff refund claims within the ACE Portal.

It enables importers to:

• Submit refund claims in bulk using structured data
• Consolidate multiple entries into a single filing
• Track claim status through ACE
• Receive refunds electronically via ACH

CAPE is now the primary method for submitting IEEPA refund claims.

Learn more.

Why are some CAPE refund claims being rejected?

CBP validates CAPE submissions at both the file level and the entry level. A declaration may be rejected if the uploaded file contains formatting issues, missing data elements or information that does not align with CBP requirements.

Recent CAPE reporting shows that while a significant number of declarations have successfully passed validation, millions of entries have failed validation checks and require correction before refund processing can continue.

Importers should carefully review entry numbers, Chapter 99 tariff classifications and CSV formatting requirements before submission. Claims that fail validation generally require correction and resubmission before they can proceed through the refund process.

How to check if my imports face reciprocal tariffs?

To determine exposure, importers should analyze HTS classifications, review applicable tariff provisions and compare them against current trade measures. ACE data can help confirm whether tariffs have been applied and whether entries may be affected by policy changes.

Where can I find U.S. reciprocal tariffs list and HS classification guidance?

Official classification guidance and tariff schedules are available through government resources such as the Harmonized Tariff Schedule and CBP rulings. These sources provide the framework for determining tariff applicability and ensuring compliance.

Who is eligible for IEEPA tariff refunds?

Eligibility depends on both the status of the entry and the party seeking the refund.

To qualify, the claimant must:

• Be the importer of record (IOR) or an authorized filer
• Have paid IEEPA-related tariffs on qualifying entries

Under the current CAPE rollout (Phase 1), eligible entries generally include:

• Unliquidated entries
• Recently liquidated entries that have not reached final liquidation status (80 days after the liquidation date) Importers should closely monitor entries approaching the 80-day post-liquidation cutoff, as those entries may be nearing the end of current Phase 1 eligibility parameters.

Entries outside these parameters will still become eligible for refunds through:

• Future CAPE phases, or
• Alternative actions such as protests or legal filings

How to identify shipments eligible for tariff refunds?

Identifying eligible shipments requires a structured review of import data.

Begin by extracting entry-level information from the U.S. Customs ACE portal, focusing on entries that include IEEPA-related tariff codes. From there, duties paid should be evaluated against what should have been assessed.

Equally important is determining whether each entry is liquidated or unliquidated. This distinction will dictate whether the refund is expected to occur automatically through liquidation or requires a formal claim.

What are the key eligibility timeframes and deadlines for filing a customs protest?

If an importer believes they’re owed an IEEPA tariff refund on liquidated entries, they can file a customs protest under 19 U.S.C. Section 1514 within 180 days of the liquidation date.

Importers would file a CBP Form 19 protest, which is used to contest decisions, including:

• The amount of duties assessed
• The classification or valuation of goods
• The application of specific tariff provisions, including IEEPA-related duties

For unliquidated entries, there’s no protest deadline in the same sense, but importers should monitor liquidation timing. Ensuring that entries are correctly classified and documented before liquidation occurs is critical because errors could affect the refund amount once CBP removes IEEPA duties.

Refunds are claimed through the ACE Portal using the CAPE tool.

High-level process:

1. Access or establish an ACE Secure Data Portal account
2. Ensure ACH enrollment is set up for refund payments
3. Compile eligible entry data
4. Prepare a CAPE declaration (CSV file)
5. Submit the declaration through CAPE
6. Monitor claim status in ACE

CBP will review the submission, recalculate duties and issue refunds for approved claims.

How long do customs tariff refund claims take?

Refund timelines are expected to vary depending on the type of entry.

For unliquidated entries, refunds may be processed more quickly as part of standard liquidation procedures. However, timing will still depend on CBP processing capacity.

CBP has indicated general processing timelines of approximately 45 to 90 days for unliquidated entries after following acceptance of the CAPE declaration.

Timing may vary based on:

• Accuracy and completeness of the filing
• Volume of claims submitted
• System performance and processing capacity

For liquidated entries, timelines are likely to be longer as liquidated entries are expected to be included in a later Phase rollout of CAPE.

How to file a tariff refund claim in the CAPE portal?

To file a claim, a CAPE CSV file must be uploaded through the importer or filer’s ACE Portal account. After logging in, users should navigate to the CAPE tab and open the file upload function.

The process generally includes the following steps:

• Click the 'CAPE' tab in the ACE Portal
• Select 'Upload' under the 'File Uploads' section
• In the 'CAPE Upload' dialog box, select the 'CAPE Upload Template' hyperlink
• Download the template provided by CBP
• Enter the required entry information into the template
• Save the completed file in CSV format
• Return to the 'CAPE Upload' dialog box
• Check the certification box confirming you are legally authorized to make the filing and have complied with applicable laws, regulations and instructions
• Upload or drop the completed CSV file for processing

Once the file is uploaded, the system will show that the upload is in progress. If the upload is successful and the declaration is validated, the file upload history will show an accepted status and generate a claim number. At that point, the importer or filer has created a CAPE declaration.

If CBP identifies issues with specific entries included in the declaration, the entries will be rejected with a specific error code and will require additional review, correction or supporting analysis before they can be successfully resubmitted or processed for refund.

CBP has reported significant differences between declarations that pass validation and those that do not. Importers should carefully review file formatting, entry-level data and all applicable IEEPA Chapter 99 tariff declarations before submission. Entries that fail validation will require correction before they can proceed through the refund process.

What documentation is needed to support tariff refund applications?

Supporting documentation should clearly connect each claimed refund amount to the original transaction. This includes entry summaries, payment records and commercial documentation, along with internally prepared calculations.

Even for unliquidated entries, maintaining complete documentation is important. CBP may still review entries before issuing refunds, and discrepancies could delay or reduce recovery.

At a minimum, you will need:

• CBP Entry Summaries (Form 7501)
• Commercial invoices
• Packing lists
• Bills of lading and arrival notices
• Duty payment details
• Purchase orders
• Documentation identifying the importer of record
• Contractual agreements addressing tariff responsibility, reimbursement obligations or duty pass-through provisions
• Entry numbers associated with IEEPA tariffs
• Applicable tariff classifications, including Chapter 99 codes
• Importer and filer ACE credentials
• Banking information for ACH refunds

All data must be formatted according to CBP requirements and submitted as a CAPE declaration file.

What tactical advice applies to post-summary corrections?

Post-summary corrections are one of the most practical tools importers have to improve the quality of their data before it’s reviewed by CBP or used to support a tariff refund claim. Given the heightened scrutiny expected around IEEPA-related entries, this isn’t just a cleanup exercise; it’s a risk management step.

Start by conducting a targeted review of your entries, focusing on the areas CBP is most likely to examine. This includes tariff classification, declared value and country of origin. These elements directly affect duty calculations, and even small inconsistencies can lead to incorrect refund amounts or trigger additional questions from CBP.

In the context of IEEPA, it’s especially important to confirm that the correct Chapter 99 provisions and duty rates were applied at the time of entry.

Where discrepancies are identified, corrections should be made as early as possible, ideally before liquidation occurs. For unliquidated entries, this is particularly important because CBP will be recalculating duties as part of the liquidation process following the CIT’s directive. If the underlying data is incorrect, the resulting refund may also be incorrect. For entries that have already liquidated, corrections should be aligned with any protest filings or refund claims to ensure consistency.

Consistency across filings is another critical factor. The data reflected in your ACE reports, internal systems, broker filings and supporting documentation should all tell the same story. Mismatches in quantities, values or classifications can slow down review or raise red flags. Taking the time to reconcile these data points upfront can significantly improve the efficiency of the claims process.

Finally, documentation should be clear, organized and audit-ready. This means not only retaining required documents such as entry summaries and invoices, but also maintaining internal work papers that explain how corrections were identified and how revised calculations were determined. If CBP reviews your claim, they should be able to follow your logic without needing extensive clarification.

In practice, companies that treat post-summary corrections as part of a structured review process, rather than a last-minute adjustment, are better positioned to support their claims and avoid delays once refund procedures are underway.

Should companies pursue litigation or administrative claims for tariff refunds?

The current direction favors administrative refund processes because the courts already resolved the core legal issue, IEEPA tariffs weren’t authorized.

The remaining work is operational, not legal. CBP has been directed to implement refunds through established processes, particularly for unliquidated entries where liquidation adjustments can address overpayments.

Litigation may still be relevant in certain cases, but for most importers, it’s unlikely to accelerate recovery. Administrative processes are expected to be the primary mechanism for both unliquidated and liquidated entries, with success driven by documentation and execution.

What are key tariff refund litigation considerations and deadlines?

For liquidated entries, the most important deadline is the 180-day protest period from the date of liquidation. Filing within this window preserves the importer’s right to challenge duty assessments and pursue refunds.

For unliquidated entries, litigation is generally less relevant because the CIT has already directed CBP to remove IEEPA tariffs during liquidation. Instead, the focus should be on ensuring that entries are accurate before liquidation occurs.

What are common mistakes in refund preparation?

Many companies underestimate the complexity of refund preparation, assuming that eligibility alone guarantees recovery.

In practice, incomplete documentation, inconsistent data and lack of internal validation are common issues that delay or derail claims. Companies that invest in thorough preparation and data integrity are better positioned to navigate CBP review successfully.

Common filing issues include incorrect entry numbers, missing Chapter 99 tariff declarations, CSV formatting errors and failure to validate data before submission through CAPE.

Where to find CBP IEEPA guidance for importers?

CBP guidance is expected through CSMS notices, regulatory updates and communications tied to Court of International Trade developments. Importers should monitor these sources closely as procedures for implementing refunds, particularly for liquidated entries, continue to evolve.

How to comply with IEEPA reciprocal trade restrictions?

Although IEEPA tariffs were invalidated, compliance obligations remain.

Importers should ensure accurate classification, maintain complete documentation and stay aligned with any new measures introduced under the Reciprocal Tariff Act. The shift away from IEEPA doesn’t reduce scrutiny on trade compliance.

How to monitor policy changes under Reciprocal Tariff Act?

Monitoring policy changes requires ongoing attention to regulatory developments, including agency updates and legislative actions. Importers should establish processes to track changes, assess their impact and adjust compliance practices accordingly.

What data is required to file a claim?

Filing an IEEPA refund claim through CAPE requires specific entry, tariff, ACE and ACH enrollment information. At a minimum, you will need:

• Entry numbers associated with IEEPA tariffs
• Applicable tariff classifications, including Chapter 99 codes
• Importer and filer ACE credentials
• Banking information for ACH refunds

All data must be formatted in accordance with CBP requirements and submitted as a CAPE declaration file.

Can multiple entries be filed together?

Yes. CAPE supports consolidated filings, allowing importers to submit multiple entries within a single declaration. This approach can help importers:

• Streamline submissions
• Reduce administrative effort
• Receive consolidated refunds

When multiple entries are submitted in a single CAPE declaration, entries can be accepted or rejected by CBP on an individual entry basis.

Can I edit a submission after filing?

No. CAPE declarations cannot be edited once submitted. If CBP rejects an entry or identifies an error in the declaration:

• A new declaration may need to be submitted for the rejected entries
• Corrections may delay processing or affect eligibility

As a result, careful data preparation and validation before submission is critical.

Do I need a customs broker or advisor to file?

No. A customs broker or advisor is not required to file a CAPE declaration, but professional support may be beneficial given the complexity of data review prior to submission. The CAPE process involves:

• Detailed data extraction and validation
• Understanding CBP requirements and eligibility rules
• Managing filings across multiple phases

Many organizations engage advisors to help reduce risk and improve efficiency.

How does Baker Tilly support tariff refund readiness?

Baker Tilly’s tariff refund and recovery services help organizations move from legal ruling to operational execution. Our global trade advisors work alongside federal, state and international tax specialists, as well as data and technology teams, to assess refund exposure, organize and validate entry data, develop defensible calculation methodologies and establish governance frameworks aligned with anticipated CBP requirements. 

We bring deep industry knowledge across manufacturing, transportation and logistics, aerospace and defense, retail, private equity and other trade-intensive sectors. This perspective allows us to tailor refund strategy, documentation readiness and tax planning considerations to the operational realities of each organization. 

By prioritizing readiness before formal refund procedures are finalized, organizations can reduce execution risk and position themselves to act decisively when filing windows open. This integrated, industry-informed approach supports timely submission, clearer administrative review and stronger confidence throughout the recovery process.