The Supreme Court struck down all IEEPA tariffs. Up to $175 billion in refunds are now available to US importers.
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Quick overview of what qualifies for an IEEPA tariff refund.
Six steps to secure your IEEPA tariff refund.
Apply at cbp.gov for an Automated Commercial Environment account. Gateway to all import records and electronic refunds. Delays are severe -- apply today.
Run the ES-003 report in ACE and export to Excel. Identify every entry with IEEPA tariff charges from Feb 4, 2025 to Feb 24, 2026.
Set up Electronic ACH payments in ACE so CBP can deposit your refund directly to your bank account.
For unliquidated entries, file a PSC to remove IEEPA duties. Must be filed within 300 days of entry date or 15 days before liquidation.
For liquidated entries, consider filing a protective action in the Court of International Trade. DOJ is expected to appeal the March 4 order.
Watch for CSMS notices. CBP is still liquidating entries with IEEPA duties post-ruling. Monitor your entries actively via ACE.
Key moments in the IEEPA tariff refund story.
Recent developments affecting your IEEPA tariff refund.
As of May 11, 8.3M of 15.1M validated entries were reliquidated without IEEPA duties — ~$35.5B principal plus interest. Some importers report refunds already received via ACH.
The CIT directs Customs to explain why IEEPA refunds shouldn't reach all entries regardless of liquidation status — a ruling that could expand eligibility beyond CAPE Phase 1.
Most importers must keep paying at the border, but trade counsel urge filing protests within 180 days of liquidation to preserve refund rights if Federal Circuit affirms the CIT ruling.
Court of International Trade rules Proclamation 11012 unlawful — administration failed to identify a "balance-of-payments deficit" as Congress defined it. Injunction limited to named plaintiffs; appeal expected.
As of Apr 14, 56,497 importers had completed ACH registration and are eligible for $127B+ in IEEPA refunds (incl. interest). Total IEEPA exposure: $166B across 330K+ importers and 53M shipments.
Important milestones for your refund claim.
| Date | Event | Status | Your Action |
|---|---|---|---|
| Feb 4, 2025 | IEEPA refund window opens (fentanyl tariffs) | Confirmed | Include all entries from this date |
| Apr 2, 2025 | Reciprocal tariff refund window opens | Confirmed | Include all entries from this date |
| Mar 7, 2025 | USMCA-qualifying Canada/Mexico goods exempt | Exception | Exclude USMCA entries after this date |
| Feb 24, 2026 | IEEPA refund window closes | Confirmed | Do not include entries after this date |
| Mar 4, 2026 | CIT orders CBP to refund all importers | In Progress | Register ACE account immediately |
| Apr 20, 2026 | CAPE Phase 1 opened for refund submissions | Live Now | File your CAPE Declaration CSV in ACE |
| May 7, 2026 | CIT strikes down Section 122 (10%) tariffs (2-1) | Limited | File protests within 180d of liquidation |
| Jul 24, 2026 | Section 122 surcharge expires by its own terms | Sunset | Compile entries with Section 122 charges now |
| 2 yrs from accrual | CIT statute of limitations | Don't Miss | File protective CIT action early |
Common questions about the IEEPA tariff refund process.
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