Importers of record who paid duties on goods assessed under the International Emergency Economic Powers Act have a recovery process to work through in 2026. The Supreme Court’s February 20, 2026 ruling invalidated tariffs imposed under IEEPA, and CBP has since opened a system to process refunds on a consolidated basis. For most finance teams, the question is no longer whether a refund path exists. It is how to document, file, and time the claim so cash comes back as quickly as the process allows.
This page covers what an IEEPA tariff refund is, who qualifies, how the CBP and CAPE process works, the timelines involved, the records worth gathering now, and the option to turn an expected refund into cash sooner through Refund Purchase.
What an IEEPA tariff refund is
IEEPA tariff refunds are recoveries of duties assessed under the International Emergency Economic Powers Act, the emergency authority used to impose certain tariffs. Once that authority was invalidated, the duties collected under it became refundable to the parties that paid them.
Not every tariff qualifies. Only IEEPA tariffs qualify for refunds. All IEEPA tariffs paid since February 4, 2025 through February 24, 2026 are eligible. That window is the boundary of the program. Duties paid under other tariff authorities sit outside this process and follow separate rules, so the first job is separating one from the other in your entry data.
Who qualifies for an IEEPA tariff refund
The claim runs through the importer of record, which is the party named on the entry, or an authorized customs broker acting on that party’s behalf. If your company is the importer of record on entries that paid IEEPA duties during the eligible window, you are the party positioned to file.
Three checks are worth running before you build a claim:
Confirm the entries. Pull entry summaries for imports between February 4, 2025 and February 24, 2026 and identify which ones included IEEPA duties.
Confirm who paid. A refund belongs to the party that paid the duty, which is not always the party that imported the goods commercially.
Confirm your contracts. Commercial terms with suppliers, brokers, and customers may spell out who keeps a refund once it arrives.
That third point is generating real friction. A growing number of lawsuits related to IEEPA tariff refunds have been filed alleging claims such as breach of contract and deceptive practices across the supply chain. Review your purchase and service agreements before filing, and involve counsel if the refund is material to your financials.
The CBP and CAPE process, step by step
CBP created the Consolidated Administration and Processing of Entries (CAPE) tool to facilitate the consolidated refund of tariffs issued under IEEPA. Beginning April 20, 2026, importers of record, or their authorized customs brokers, may submit IEEPA tariff refund requests electronically through the ACE Secure Data Portal. Approved refunds are consolidated and issued electronically by ACH.
Determine eligibility entry by entry and confirm the duties in question were IEEPA duties.
Assemble supporting documentation for every entry you plan to claim.
Submit the refund request through CAPE, either directly or through your authorized customs broker.
Answer any CBP questions that come up during the review period.
Receive the consolidated refund electronically by ACH once the claim is accepted.
Because CAPE consolidates claims, the quality of your underlying records does most of the work. Incomplete entry data or mismatched payment records tend to slow a claim rather than sink it, but the delay is measured in weeks. Fixing records before you file is almost always cheaper than fixing them mid-review.
How long IEEPA tariff refunds take
For most entries, importers can expect refunds within 60 to 90 days of CAPE Declaration acceptance, accounting for the 45-day CBP review period. Those figures describe the general expectation, not a fixed promise on any single entry.
Stage | What happens | Timing | |
|---|---|---|---|
Submission | Refund request filed through CAPE via the ACE Secure Data Portal | Begins April 20, 2026 | |
CBP review | CBP reviews the claim and supporting entry data | 45 days | |
Acceptance | Claim accepted and consolidated with other approved refunds | A | t the end of the review period |
Payment | Refund issued electronically by ACH | Typically within 60 to 90 days of CAPE Declaration acceptance |
Treat these windows as planning assumptions rather than fixed dates. Confirm current timing with CBP guidance or your customs broker before you commit them to a cash forecast.
Documents and records to gather
Preparation is the part you control. Start by determining your company’s eligibility, then gather documentation and shore up the controls around it. The list below covers what most importers need on hand.
Entry summaries and entry documentation for the eligible period
Proof of duty payment for each entry claimed
Broker records and any power of attorney authorizing a broker to file on your behalf
Internal records tying each entry to a purchase order, invoice, and shipment
Contracts with suppliers, customers, and service providers that address tariff costs or refunds
A governance file showing who reviewed the claim and what controls were applied
Importers who built this file before filing move faster. Importers who start after submitting spend the entire review period chasing paper. If your entries are numerous or your broker handles the filing, agree early on who owns each document and where it lives.
Deadlines and risk factors to watch
Deadlines in this process are set by CBP and by the courts, and they have shifted during 2026. Rather than rely on a secondhand date, verify the current filing window with official CBP sources or your customs broker before you plan around it.
Two other risks deserve attention. The first is commercial. Suppliers who absorbed tariff costs may argue the refund belongs to them, and those disputes are already in litigation. The second is documentation risk. Claims resting on weak entry data invite questions that stretch the review period and can reduce what is ultimately refunded.
Getting cash sooner with Refund Purchase
A refund that arrives 60 to 90 days after acceptance is still cash tied up in a government process. For importers with meaningful duty exposure, that gap can land in the same quarter as supplier payments, payroll, and inventory purchases.
Refund Purchase is the purchase of a tariff refund receivable. Instead of waiting for CBP to issue payment, a business sells the filed refund and receives cash before the government pays. The refund still moves through the same CBP process. What changes is who waits for it.
This option fits importers who meet a few conditions:
The refund amount is documented and tied to identifiable entries
The claim has been filed through CAPE
The business needs liquidity this quarter more than it needs the full refund amount later
Internal stakeholders agree on the cost of waiting versus the cost of selling the receivable
Refund Purchase is a business transaction, not a bet on the outcome. Review the terms with your own advisors and decide whether the tradeoff suits your cash planning. If your refund is modest or your cash position is comfortable, waiting out the CBP timeline may be the simpler path.
Frequently Asked Questions
Which tariffs qualify for an IEEPA refund?
Only IEEPA tariffs qualify for refunds. Duties assessed under other tariff authorities follow separate rules and separate processes. The eligible window covers all IEEPA tariffs paid since February 4, 2025 through February 24, 2026. If you are unsure which authority applied to a specific entry, check the entry documentation or ask your customs broker to confirm before filing.
How long does it take to receive an IEEPA tariff refund?
For most entries, refunds are expected within 60 to 90 days of CAPE Declaration acceptance, which accounts for the 45-day CBP review period. Approved refunds are consolidated and issued electronically by ACH. Timing can vary from entry to entry, so treat these figures as planning assumptions and confirm current expectations with CBP guidance or your broker.
Do I need a customs broker to file a refund request?
Importers of record can submit IEEPA tariff refund requests electronically through the ACE Secure Data Portal, and authorized customs brokers may submit on their behalf. Many companies use their broker because the broker already holds the entry data and filing permissions. Either route works, but the importer of record stays responsible for the accuracy of the claim.
Can I get the money before CBP pays the refund?
Yes, through Refund Purchase. That program is the purchase of a tariff refund receivable, which means the business sells its expected refund and receives cash before the government issues payment. The CBP process continues as normal. Review the terms with your own advisors to judge whether the cost of selling the receivable fits your cash needs.
Who keeps the refund if my supplier paid the tariff?
The refund follows the party that paid the duty, and that party is not always the commercial importer. Contracts with suppliers, brokers, and customers may specify who retains a refund once it is issued. Because lawsuits alleging breach of contract and deceptive practices have already been filed over tariff refunds, review your agreements with counsel before filing a claim that may be contested.