Which IEEPA Tariff Orders Are Covered by the Refund Window? A Country-by-Country Breakdown

When the U.S. Supreme Court struck down IEEPA tariffs as unconstitutional in February 2026, importers across every industry suddenly had a potential refund claim on their hands. But the ruling did not create a single uniform refund opportunity. The IEEPA tariff landscape is built from several distinct executive orders, each targeting a different country or set of countries, each carrying its own duty rate and effective date, and each tied to a specific filing deadline. Understanding which orders apply to your imports is the first step toward recovering what you overpaid.

Why the Country of Origin Determines Your Deadline

CBP administers IEEPA tariff refund claims through the CAPE portal, and the deadline for each claim traces back to the legal basis of the order that imposed the duty. Two distinct deadline categories exist. Importers whose goods entered from China, Mexico, or Canada under the fentanyl-justified IEEPA orders must file by February 4, 2027. Importers whose goods entered from all other countries under the so-called reciprocal tariff orders have until April 5, 2027.

Missing either deadline almost certainly means losing the refund permanently. CBP has given no public indication that it will extend these windows, and the statutory authority for extensions is narrow. If you import from multiple countries of origin, you may face both deadlines simultaneously and need to prioritize accordingly.

The Fentanyl Orders: China, Mexico, and Canada

The earliest IEEPA tariff actions were framed around the administration's declared national emergency related to fentanyl trafficking. These orders imposed additional duty rates on goods originating from China, Mexico, and Canada beginning in early 2025. The rates varied by country and were amended multiple times, which means the recoverable amount for any given shipment depends on which version of the order was in effect on the date of entry.

For China, IEEPA duties were layered on top of existing Section 301 tariffs, creating a stacked rate that pushed some importers into effective duty burdens of 50 percent or more on certain product categories. Section 301 tariffs are not part of the IEEPA refund opportunity, but the IEEPA portion is. Separating the two is a technical exercise that requires reading the entry summary line by line.

For Mexico and Canada, many importers were already navigating USMCA qualification questions when the IEEPA duties landed. Goods that qualified for USMCA treatment were sometimes assessed IEEPA duties anyway, and those entries are now among the most commonly eligible for refund claims. The February 4, 2027 deadline applies to all three countries in this group.

The Reciprocal Tariff Orders: Broader Country Coverage, Later Deadline

Beginning in April 2025, the administration imposed a separate wave of IEEPA tariffs framed as reciprocal measures targeting trade partners across Asia, Europe, and other regions. These orders covered an extraordinarily wide range of countries and product categories. Some rates were applied universally at a baseline level, while others were elevated for specific trading partners based on the administration's tariff gap calculations.

Countries affected by the reciprocal orders include major U.S. import sources such as Vietnam, India, Taiwan, South Korea, Japan, the European Union member states, the United Kingdom, and dozens of others. If your supply chain runs through any of these origins and your goods entered the U.S. between approximately April 2025 and the date of the Supreme Court ruling, you likely have a recoverable claim. The filing deadline for this group is April 5, 2027.

How Duty Stacking Affects the Size of Your Claim

One of the most important details importers miss is that IEEPA duties were almost always assessed on top of existing duty obligations. Your base MFN rate still applied. Section 301 tariffs on Chinese goods still applied. Section 232 steel and aluminum tariffs still applied where relevant. The IEEPA rate was an additional layer on top of all of that.

What this means for your refund claim is that the recoverable amount is specifically the IEEPA portion, not the entire duty payment on the entry. Identifying that portion requires pulling your ACE entry summary data, isolating the duty lines assessed under the relevant IEEPA HTS subheadings or special program indicators, and summing those amounts across all entries within the eligible period.

For importers with high import volume, this calculation can run into hundreds of individual entries. The good news is that CBP already holds this data in ACE, and it can be extracted and analyzed before you file a single claim.

What the CAPE Portal Requires for Each Country Group

CBP's CAPE portal is the designated filing system for IEEPA tariff refund claims. A separate claim must generally be filed for each affected entry, meaning high-volume importers face a significant documentation burden. Each claim requires the entry number, the import date, the IEEPA duty amount being claimed, and supporting entry summary documentation.

The portal does not distinguish automatically between fentanyl order entries and reciprocal tariff entries. That categorization falls to the filer. Filing a China, Mexico, or Canada entry under the wrong legal basis or beyond the February 4, 2027 cutoff will result in denial. Accurate entry-by-entry classification is not optional.

Statutory Interest Adds to the Total

Every approved IEEPA tariff refund carries statutory interest calculated from the original payment date through the date of repayment. For duties paid in early 2025, that interest has been accruing for two years or more by the time refunds are issued. The interest rate is set by statute and applied automatically; you do not need to calculate or request it separately. It is simply built into the ACH payment CBP issues after approval.

For importers with large duty payments made in the early months of the IEEPA tariff period, the interest component can represent a meaningful addition to the base refund amount. This is one reason filing sooner rather than later benefits you: the refund timeline runs roughly 60 to 90 days from filing to payment, and the sooner you file, the sooner you stop waiting.

Roughly 93.5 Percent of Eligible Importers Have Not Filed

CBP has processed approximately $121.75 billion in IEEPA tariff refund claims to date. That sounds significant until you consider that an estimated 93.5 percent of eligible importers have still not submitted a claim. The reasons vary. Some importers are unaware the refund window exists. Others are unsure whether their specific country of origin and product category qualifies. Many simply do not have the internal resources to work through hundreds of entry summaries while running a business.

The filing deadlines are real and non-negotiable. Every month of delay is a month closer to losing a recoverable asset permanently.

Check Your Eligibility with Tarisol

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 model. There is no upfront cost, and you pay nothing if no refund is recovered.

Whether your imports come from China, Vietnam, Mexico, the European Union, or any other country affected by IEEPA tariff orders, Tarisol can help you determine what you may be owed, which deadline applies, and how to file accurately before the window closes. Reach out to Tarisol today to start your eligibility review and protect your right to recover duties you should never have paid.