- Julio Rodriguez US Customs Broker
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IEEPA tariff refunds and CAPE: the complete guide
The largest customs refund event in memory is underway. If your company paid the 2025 IEEPA tariffs, this guide covers what fell, how CAPE works, who CBP will actually accept a claim from, and which clocks are real once you strip out the ones being sold to you.
Published September 19, 2026 · Updated September 30, 2026. Refund facts verified as of this date; deadlines and program details can change.
What happened, in four dates
February 20, 2026: the Supreme Court held in Learning Resources v. Trump, 6 to 3, that IEEPA does not authorize tariffs. The 2025 reciprocal tariffs and the fentanyl-order tariffs lost their legal basis.
February 24, 2026: CBP stopped collecting the struck tariffs.
April 20, 2026: CBP opened CAPE, the refund tool inside ACE, to process the give-back.
September 11, 2026: the running tally reached roughly $134.7 billion in accepted declarations and about $122 billion, duties plus interest, certified to the Treasury for payment, on more than 200,000 declarations. The figures come from CBP's own declarations to the Court of International Trade; CBP publishes no running total on its website. The refunds are not theoretical, and they are not only for the companies that sued.
How a CAPE filing actually works
CAPE lives inside ACE, and CBP accepts declarations only from the importer of record or its licensed customs broker. That is not a formality; preparing refund filings for others is customs business under 19 USC 1641 and requires a license. The declaration identifies the affected entries and the IEEPA amounts paid; CBP verifies against its own records and pays with interest, on a timeline that has been running roughly 60 to 90 days from acceptance.
The practical work is entry forensics: pulling your entry history, isolating the IEEPA lines from ordinary duties and other special tariffs, and handling entries in different liquidation states through the right channel. This is the part a broker's records access makes fast.
The clocks that actually run
CBP has announced no deadline for filing a CAPE claim. Say that plainly, because the countdown is the favorite instrument of the firms working this wave, and it is not a real one.
The clocks that do run belong to your entries, one each. While an entry is unliquidated, or liquidated within the last 80 days, it goes through CAPE. Past that, a protest under 19 USC 1514 runs 180 days from the liquidation notice posted on cbp.gov. Past that, the entry is finally liquidated and the administrative doors are shut.
For that last group the remaining route is a suit at the Court of International Trade, and the outside limits work out to February 4, 2027 for the fentanyl orders and April 5, 2027 for the reciprocal tariffs. Those dates come from a two-year statute of limitations rather than from any CBP announcement, and CBP's own tool for finally liquidated entries is not deployed, with the court order it depends on under appeal. If your 2025 entries are in that group, the conversation is worth having now and it is a conversation that includes trade counsel, not only a broker.
Tariff refunds
Paid IEEPA or Section 301 tariffs? Find out what you can get back.
Licensed customs brokers since 2007, filer code EWV. We file your refund under our own license: IEEPA claims through CAPE, protests, post-summary corrections and duty drawback. Priced per entry and quoted before you commit, with no percentage of your refund.
FAQ
Am I eligible for an IEEPA refund if I never filed a lawsuit?
Yes. The refunds flow to any importer who paid the struck tariffs, and CBP estimates roughly 330,000 importers paid the tariffs. Filing through CAPE is what claims your share.
How do I know how much IEEPA tariff I paid?
It is on your entry summaries, line by line. A licensed broker can pull your entry history from ACE and isolate the IEEPA amounts from ordinary duties, which is the first step of any filing we do.
Is there interest on CAPE refunds?
Yes, refunds are paid with interest. The roughly $122 billion certified for payment by September 11, 2026 is duties plus interest, under 19 USC 1505.
What if my entries have already liquidated?
It depends how long ago. Liquidated within the last 80 days, CAPE still takes them. Within 180 days, a protest under 19 USC 1514 is the route. Beyond that they are finally liquidated, CBP's own tool for that group is not deployed, and the remaining path is a suit at the Court of International Trade with outside limits around February 4 and April 5, 2027. That last one is trade counsel territory and we will say so rather than pretend it is a filing we can make for you.
Have a licensed broker check your 2025 entries
We pull the entry history, isolate the IEEPA amounts, and file through CAPE as your broker. Flat per-entry pricing, quoted before you commit.
CTPAT certified broker · EWV