First-Time Importer's Checklist for Filing an IEEPA Tariff Refund Claim

The U.S. Supreme Court ruled IEEPA tariffs unconstitutional in February 2026, opening a refund window that many importers have not yet touched. Refund deadlines fall on February 4, 2027, for fentanyl-related tariffs on goods from China, Mexico, and Canada, and on April 5, 2027, for reciprocal tariffs on goods from other countries. If you have never filed a tariff refund claim before, the paperwork and portal requirements can look daunting. This checklist breaks the entire process into concrete, sequential steps so you know exactly where to start and what to have ready before you submit anything.

Step 1: Confirm You Are the Importer of Record

Refund eligibility belongs to the importer of record (IOR) for each entry, not to the foreign supplier, the freight forwarder, or the ultimate buyer. Pull your entry documentation and verify that your Employer Identification Number (EIN) or Customs Assigned Number appears as the IOR on the entry summaries. If a customs broker filed entries on your behalf, ask them to confirm this detail in writing before you invest time in the rest of the checklist.

If ownership of your business changed after the entries were filed, the right to claim refunds may have transferred to the acquiring entity. That situation is more complex, but it does not automatically disqualify you. Document the chain of ownership clearly.

Step 2: Gather Your Entry Summaries (CBP Form 7501)

Every IEEPA tariff refund claim is anchored to specific entry summary numbers. CBP Form 7501, the entry summary, shows the duty paid, the HTS code used, the country of origin, and the tariff program that applied. You need this document for each entry you plan to include in your claim.

If you do not have copies on file, your licensed customs broker should be able to pull them. You can also retrieve entry data directly from the Automated Commercial Environment (ACE) portal if your account is already set up. Entries spanning the relevant tariff periods are the ones worth reviewing first.

Step 3: Identify Which Tariff Columns Were Charged

Not every duty line on an entry summary is refundable. You are looking specifically for charges assessed under the IEEPA tariff orders that the Supreme Court struck down. On entry summaries, these often appear as Chapter 99 HTS codes layered on top of the base Column 1 duty rate. Common examples include the 10 to 145 percent additional tariffs placed on Chinese goods and the tariffs applied to goods from Mexico and Canada under the fentanyl executive orders.

Separate any Section 301 tariffs from the IEEPA charges. Section 301 tariffs remain in a different legal posture and follow a different recovery path. Mixing them in your analysis will create confusion when you get to the filing stage.

Step 4: Verify Country-of-Origin Documentation

CBP requires that the country of origin declared on your entry matches the supporting documentation. For refund purposes, the country of origin is what determines which tariff order applied and therefore which refund window covers your goods. Gather the commercial invoices, bills of lading, and any certificates of origin or manufacturer affidavits that substantiate the origin declaration on each entry you plan to claim.

Weak or missing origin documentation is one of the most common reasons a refund claim gets delayed or rejected. Resolving documentation gaps now, before filing, protects your claim.

Step 5: Set Up or Confirm Your ACE Portal Access

The CAPE portal, where IEEPA tariff refund claims are submitted, sits inside the ACE portal environment. If you do not already have an ACE account, you will need to create one through CBP's trade.gov registration process. Allow several business days for account approval and role assignment. If you already have an ACE account, verify that you have access to the importer account linked to your EIN, not just a broker-level or filer account.

ACE access is a prerequisite even if you are working with a licensed specialist who files on your behalf, because Power of Attorney documentation must be associated with your ACE importer profile.

Step 6: Complete ACH Enrollment for Electronic Payment

CBP issues approved refunds by ACH direct deposit. If you are not enrolled in the CBP ACH refund program, you will not receive payment electronically and the process will slow down significantly. Enrollment requires your bank routing number and account number submitted through your ACE account settings. This step is easy to overlook because it happens outside the actual claim filing workflow, but it must be in place before your refund can disburse.

Once enrolled, approved refunds including statutory interest typically arrive within 60 to 90 days of a successful claim.

Step 7: Execute a Power of Attorney if Using a Specialist

Most first-time filers work with a licensed filing specialist rather than navigating the CAPE portal alone. If you choose that route, you will need to execute a customs power of attorney (POA) authorizing the specialist to act on your behalf. The POA must be specific to customs transactions and signed by an authorized officer of your company. Your specialist will provide the form, but make sure your corporate records can support the signatory's authority if CBP ever requests verification.

Step 8: Calculate Your Estimated Recoverable Amount

Before you file, run a basic estimate of what you might recover. Add up the IEEPA duty amounts across all entries you have identified. Remember that statutory interest accrues from the date of payment, so older entries will carry more interest than recent ones. This exercise also helps you prioritize which entries to include if you have hundreds of shipments, since entries with higher duty payments deserve the most attention first.

You do not need an exact number to move forward, but a reasonable estimate helps you evaluate whether working with a success-based specialist makes financial sense for your situation.

Step 9: Review Your Records for the Required Retention Period

CBP can request supporting documentation after a claim is filed. Under standard recordkeeping rules, importers must retain entry-related records for five years from the date of entry. Confirm that your commercial invoices, packing lists, bills of lading, and entry summaries for the relevant periods are stored and retrievable. Digital copies are acceptable as long as they are legible and complete.

Step 10: File Before the Deadline

No amount of preparation matters if you miss the filing window. Mark February 4, 2027, for fentanyl-tariff entries and April 5, 2027, for reciprocal-tariff entries on your calendar now. Given that CBP has processed approximately $121.75 billion in claims and roughly 93.5 percent of eligible importers have not yet filed, the portal will likely see a surge of activity as deadlines approach. Filing early avoids last-minute technical problems and gives your specialist time to correct any deficiencies before the window closes.

Check Your Eligibility With Tarisol

If any step in this checklist revealed entries you have not yet reviewed, now is the time to act. Tarisol connects U.S. importers with the Tariff Refund Agency, a licensed specialist that files IEEPA tariff refund claims through CBP's CAPE portal on a success-based fee structure with no upfront cost. Visit Tarisol to check your eligibility, get a no-obligation estimate of your recoverable duties, and find out how quickly your claim can be prepared and submitted before the 2027 deadline.