IEEPA Tariff Refund Guide: Deadlines, Eligibility, and How to File in 2026

If your business imported goods into the United States in 2025, you likely paid tariffs that a federal court has since ruled were unconstitutional. That money can be recovered, but only if you file before strict deadlines most importers do not know about.

What Are IEEPA Tariff Refunds?

In February 2026, the U.S. Supreme Court ruled 6-3 that President Trump's tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unconstitutional. The ruling invalidated tariffs in effect since early 2025, including:

• Fentanyl tariffs: applied to goods from China (20%), Mexico (25%), and Canada (25%), effective February 4, 2025
• Reciprocal tariffs: applied to goods from most other trading partners at varying rates, effective April 5, 2025
• Baseline tariffs: a 10% universal baseline applied broadly starting April 5, 2025

More than 330,000 U.S. importers paid approximately $166 billion in IEEPA duties. As of mid-2026, approximately $100 billion has been refunded to major corporations, but tens of thousands of small and mid-size importers have not yet filed claims.

Who Qualifies for an IEEPA Tariff Refund?

You may qualify if all of the following are true:

• You were the Importer of Record (IOR): the party that paid the tariff to CBP
• You paid IEEPA duties between the covered dates: Feb 4, 2025 through Feb 24, 2026 (fentanyl) or Apr 5, 2025 through Feb 24, 2026 (reciprocal)
• Your goods were subject to IEEPA: not Section 301, Section 232, or Section 201 tariffs

IEEPA refunds do not cover Section 301 tariffs (most China tariffs from 2018), Section 232 steel and aluminum tariffs, Section 201 tariffs, or anti-dumping and countervailing duties.

The Deadlines You Cannot Miss

Miss the deadline and your refund is permanently forfeited. Given the time needed to gather entry data, work with a specialist, prepare the CAPE Declaration, and allow for CBP review, importers who wait until January 2027 may not receive their refund in time.

How the CAPE Portal Works

CBP created the Consolidated Administration and Processing of Entries (CAPE) system within its Automated Commercial Environment (ACE) portal to process IEEPA refund claims.

• CAPE Phase 1: opened April 20, 2026. Covers unliquidated entries and entries within 80 days of liquidation.
• CAPE Phase 2: opened June 29, 2026. Covers reconciliation entries.

Once a CAPE Declaration is submitted and accepted, refunds are issued via ACH within approximately 60 to 90 days, including statutory interest.

How Tarisol Helps

Tarisol connects U.S. importers with the Tariff Refund Agency, a licensed specialist that handles the entire process (entry review, CAPE Declaration preparation, and CBP filing) at no upfront cost.

1. Check eligibility: free, takes minutes
2. Entry review: licensed specialists analyze your import data
3. Claim filing: CAPE Declaration submitted through CBP's ACE system
4. You get paid: refund deposited via ACH, fees only from the recovered amount