- Julio Rodriguez US Customs Broker
- Refund checker
Which duty refund doors are open on your entry?
Five questions, no email, nothing stored. You get the routes that appear open on what you told us, the ones that are closed and the reason, and the ones only your entry records can decide.
Refund rules are not one rule. CAPE, protest, post summary correction, drawback and a suit at the Court of International Trade are five different doors with five different clocks, and the wrong one gets a claim rejected rather than paid.
This tool reads your five answers against the published rules and tells you which door fits. It does not look at your entry summaries, so it can narrow the question and it can never settle it.
Every refund route, in full
The complete rule set the checker above reads from, whether or not you answer anything. Each entry says what the route is, who may file it and which authority says so.
- No IEEPA duty was collected on this entry
CBP collected the IEEPA tariffs between 4 February 2025 and 24 February 2026, when Executive Order 14389 ended the nine programs and collection stopped. Goods that arrived outside those dates did not pay them, whatever the invoice looked like.
What to do next. Read the entry summary line by line. Section 301, Section 232 and the Section 122 surcharge all appeared on entries in the same period and are often remembered as the same thing.
Authority: EO 14389, CSMS 67834313
- CAPE declaration, entry still open
Refunds of IEEPA duty do not arrive on their own. CBP does not reliquidate on its own initiative for this class, so no declaration means no refund. The Consolidated Administration and Processing of Entries (CAPE) process takes a CSV of up to 9,999 entry numbers uploaded in the ACE portal with a certification, and CBP has announced no deadline for the declarations open to every importer.
What to do next. Check the entries first, then file once. Once a declaration is accepted it cannot be amended or cancelled. Accepted open entries are set to liquidate 45 days out and refunds generally issue 60 to 90 days from acceptance, by ACH only, with interest under 19 USC 1505.
Authority: CBP IEEPA Duty Refunds, CSMS 68340863
- We need the liquidation date before anything else
Almost every clock on this page runs from liquidation, so without that date the answer is a guess. The legal evidence is the bulletin notice posted on cbp.gov, and the date also appears against the entry in your ACE portal account.
What to do next. If you have an ACE account, look under the entry summary. If you do not, we can pull the entry list for your importer of record number and read the dates off the posted notices with you.
Authority: 19 CFR 159.9
- CAPE, once we know how long ago it liquidated
CAPE takes entries that are still open, and entries that liquidated no more than 80 days ago. The cutoff is not arbitrary: CBP may reliquidate on its own initiative only within 90 days of liquidation, so 80 days leaves it room to process.
What to do next. Give us the liquidation date and this becomes a yes or a no rather than a maybe.
Authority: 19 USC 1501
- CAPE declaration, liquidated inside the 80 days
The entry liquidated recently enough that CAPE still accepts it. The window closes 80 days after the liquidation date, because CBP's own authority to reliquidate runs out at 90 and it keeps a processing buffer.
What to do next. This is the one route on the page with a real countdown. Get the entry list assembled now, and remember that an accepted declaration cannot be amended afterwards.
Authority: 19 USC 1501, CBP IEEPA Duty Refunds
- Protest, because CAPE's window has passed
More than 80 days past liquidation, CAPE will not take the entry, but a protest under 19 USC 1514 still can, for 180 days from the date of the posted bulletin notice. Not from the entry date, and not from a courtesy notice.
What to do next. Two traps worth naming. An entry with an open or suspended protest is CAPE-ineligible, so do not protest an entry you meant to put on a declaration. And a protest filed only to claim an IEEPA refund can be withdrawn so the entry moves into CAPE, if the timing still allows it.
Authority: 19 USC 1514, 19 CFR 174.12(e)
- A suit at the Court of International Trade
Once an entry is finally liquidated, no administrative route reaches it. CAPE Phase 3, the phase that covers finally liquidated entries, is scheduled to open on October 6, 2026, and only for plaintiffs whose entries the court ordered reliquidated; those who gave CBP a valid importer number by July 30, 2026 file from the first day. CBP said so in a declaration to the court filed September 15, 2026. The court order the remedy depends on is itself on appeal at the Federal Circuit.
What to do next. That leaves a civil action, which is trade counsel's work and not a broker's. The two dates circulating for these suits, early February and early April 2027, are a practitioner computation from the two-year limit and the tariff start dates. No CBP document and no court order publishes them as deadlines, so treat them as a planning horizon and talk to counsel well before either.
Authority: 28 USC 1581(i), 28 USC 2636(i), V.O.S. Selections ECF 82
- An IEEPA refund can never be requested by post summary correction
No, and this is the single rule most likely to get a refund request rejected. CBP states it plainly in its own webinar material: the trade is prohibited from initiating an IEEPA duty refund request by filing a post summary correction.
What to do next. Use CAPE while the entry qualifies, a protest after that, and counsel once the entry is finally liquidated. Note the contrast, because it confuses people constantly: a different broker CAN file a PSC on another filer's entry with your power of attorney, but no broker other than the original filer can file a CAPE declaration.
Authority: CBP Pub. 5525-0426
- Section 122 surcharge, protest within 180 days
There is no administrative refund program for the Section 122 surcharge, so the only routes are a protest within 180 days of liquidation and a suit at the Court of International Trade. Entries ran from February to July 2026 and liquidate roughly ten months after entry, which means these windows are opening right now.
What to do next. Find the liquidation dates and diary them. A protest filed one day before the notice is posted is void, and one filed on day 181 is too late.
Authority: 19 USC 1514, CIT Slip Op. 26-47
- There is no CAPE for the Section 122 surcharge
The surcharge was collected under Proclamation 11012 from February 24 to July 23, 2026, when it expired at its 150-day statutory maximum. The Court of International Trade held it unlawful in May 2026 but limited relief to the three plaintiffs before it, and the Federal Circuit stayed that decision.
What to do next. Do not wait for a program to be announced. Protect the entries with a protest on time, and if the goods were exported, drawback applies to this surcharge as well.
Authority: Proclamation 11012, 91 FR 9339, CSMS 67844987 (drawback available on the surcharge)
- Drawback, five years from the date of importation
Drawback returns 99% of the duty on goods that were imported and then exported or destroyed. The clock is five years from the date of importation, meaning the day the goods arrived in the customs territory, not the entry date. The export or destruction has to fall inside those five years too. Ordinary duty, marking duty, the merchandise processing fee and the harbor maintenance fee all come back, and Section 301, 201 and 122 duties are eligible.
What to do next. Two things decide whether this is real. The claimant is the exporter or destroyer by default, not the importer, unless that right is waived to you in writing. And the export notice below has to have been filed on time.
Authority: 19 USC 1313(r), 19 CFR 190.3, 19 CFR 190.33, 19 CFR 101.1
- The export notice that quietly ends most drawback claims
CBP Form 7553 has to be filed at least 5 working days before the goods are exported, or 7 before destruction, so CBP has the chance to examine them. The only way around it is the prior notice privilege under 19 CFR 190.91, and that privilege is prospective: it does not cover shipments that already left.
What to do next. If goods have already gone without a notice, say so early rather than late. The claim may be gone, and only someone reading the actual shipment records can tell you. If more exports are coming, the privilege is worth applying for now.
Authority: 19 CFR 190.35, 19 CFR 190.91
- Order of operations: CAPE first, then drawback
Where the same entries carry IEEPA duty and are also drawback candidates, CBP's instruction is to put them on the CAPE declaration first and file the drawback claim afterwards. Drawback entry type 047 is not eligible for a CAPE declaration, so doing it the other way around closes a door you wanted.
What to do next. Sequence the two filings deliberately. This is a planning question, and it is cheap to get right and expensive to get backwards.
Authority: CBP IEEPA Duty Refunds
- Section 232 duty: drawback depends on which proclamation
It depends on the commodity, because each Section 232 proclamation sets its own rule. Section 232 depends on which proclamation covers the goods, because each sets its own rule. Timber and lumber (Proclamation 10976) and pharmaceuticals (11020) allow drawback in full. Medium and heavy trucks and auto parts (10984), polysilicon (11052), drones (11055), and steel, aluminum and copper made from treaty-partner metal entered on or after April 6, 2026 (11021) allow manufacturing drawback only, under 19 USC 1313(a) and (b). Copper under Proclamation 10962, semiconductors (11002), finished automobiles (10908) and steel and aluminum entered before April 6, 2026 bar it. Manufacturing drawback means the imported article was used to make the exported one; unused-merchandise claims are not allowed where only manufacturing drawback is. Section 301, 201 and 122 duties on the same entry remain eligible.
What to do next. Have the proclamation matching your commodity identified before anyone quotes you a recovery figure, because the older blanket citations are now out of date.
Authority: Proclamations 10908, 10962, 10976, 10984, 11002, 11020, 11021, 11052, 11055
- Antidumping and countervailing duty cannot be drawn back
Barred by regulation and by statute, with no exception to work toward. This one is worth knowing early, because AD/CVD is often the largest number on the entry and it is the number people assume is recoverable.
What to do next. Leave it out of the recovery estimate. The ordinary duty, the fees and the eligible trade-program duty on the same entry can still be claimed.
Authority: 19 CFR 190.3(b), 19 USC 1677h
- Antidumping and countervailing duty: a narrow protest, not a refund route
Commerce's substantive determination is not protestable to CBP. What is protestable is CBP's own ministerial act at liquidation: the wrong rate keyed, the wrong case number applied, or an entry liquidated in violation of a suspension.
What to do next. If you think the rate on the entry does not match the instruction Commerce issued, that is a real protest and it runs on the same 180 days. Send the entry number and the case number.
Authority: 19 USC 1514(b), 19 USC 1516a
- Post summary correction, while the entry is still open
A PSC is available within 300 days of the entry date and no later than 15 days before the scheduled liquidation, whichever comes first. Because CBP usually liquidates a little over ten months after entry, the 15-day limb is the one that binds in practice. The entry has to be accepted, fully paid, unliquidated, not under review and not tied to a protest.
What to do next. Two exceptions lift the 300-day cap, though never the 15-day rule: a granted liquidation extension, and, since July 2026, entries suspended for antidumping, countervailing, EAPA or an injunction. Since 5 August 2026 a duty increase on a PSC must be paid by ACH, and no further PSC may be filed on the entry until it clears. Note also that a PSC cannot make a post-importation trade agreement claim: that is a different filing entirely.
Authority: 19 CFR 101.9(b), 91 FR 41053
- Protest, 180 days after the entry liquidated
It runs from the date of the bulletin notice posted on cbp.gov, which is the legal evidence of liquidation, and it cannot be filed before that. A protest filed early is void, not merely early. A customs broker who holds your general power of attorney need only sign it, with no protest-specific authorization.
What to do next. Ask for further review on the same form inside the same 180 days if the issue is worth it. Accelerated disposition, sent by certified or registered mail, deems the protest denied on day 30 and turns an open-ended review into a date you can plan around, with 180 days from denial to go to court.
Authority: 19 USC 1514
- The Section 301 exclusion window that opened in September 2026
Yes, one. Conforming amendments published on 2 September 2026 added statistical numbers to existing exclusions, retroactive to 1 July 2026. Entries whose July and August lines fell under those new statistical categories can now claim the exclusion. Those entries are only weeks old, so they are still unliquidated and this is a post summary correction rather than a protest.
What to do next. Two dates to hold together. This is the only currently open retroactive exclusion window, and all 178 Section 301 exclusions lapse on 9 November 2026. Any classification review worth doing is worth doing before then.
Authority: 91 FR 56538
- Demurrage, per diem, storage and exam costs are not a refund
These are commercial charges from the carrier, the terminal or the exam site, not duty collected by CBP. There is no claim against the government for them, and the importer generally bears the cost of an examination.
What to do next. The place to work on these is your carrier and terminal terms, and the free-time clock. It is not a filing, and anyone offering to recover them from CBP is selling something that does not exist.
Authority: 19 USC 1467
- Puerto Rico excise tax and sales tax are not CBP money
Puerto Rico is inside the customs territory of the United States, so every federal route on this page works exactly the same there. But the Puerto Rico excise tax and the sales and use tax are administered by Hacienda through SURI, not by CBP, and no CBP refund route touches them.
What to do next. Keep the two ledgers apart. We handle the CBP side and tell you plainly which line belongs to Hacienda, so nothing gets filed at the wrong agency.
Authority: 19 CFR 101.1, 19 USC 1401(h)
- No refund is paid at all without ACH enrolment
Since 6 February 2026 every CBP refund is electronic. A payee with an ACE portal account has to enroll under the ACH Refund Authorization tab, and a perfectly valid CAPE, PSC or protest refund simply sits there until they do. Almost nobody mentions this.
What to do next. Enroll before you file anything, not after. It costs nothing and it is the difference between a refund landing in 60 days and a refund landing whenever somebody notices.
Authority: FR Doc. 2025-24171
- There are no refunds on former de minimis shipments
No, and it is kinder to say so in one line than to leave hope. The exemption was suspended in 2025 by executive order, the order that ended the IEEPA tariff programs did not restore it, and CBP's interim final rules of 24 June 2026 rest independently on the statute rather than on IEEPA. The Court of International Trade upheld that suspension in August 2026, and the statutory repeal of commercial de minimis lands on 1 July 2027.
What to do next. One genuinely open question sits next to this and we will not pretend otherwise: the separate postal duties charged from August 2025 to February 2026 were not named in the termination, and whether those specific duties are refundable is unresolved. If that is your situation, it is worth a conversation rather than an answer from a web page.
Authority: EO 14388, 19 CFR 10.151(b), CIT Slip Op. 26-94
This is orientation, not legal advice. Only your entry records decide what is actually claimable, and a licensed customs broker has to confirm it before anything is filed. Nothing you type here is stored or sent anywhere.
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