IEEPA Tariff Refund Guide: How Customs Brokers Can Recover Duties Through CAPE

The Supreme Court's decision to strike down IEEPA tariffs on February 20, 2026 sent shockwaves through the trade community. For the first time since the tariffs were imposed, importers and customs brokers now have a clear path to recovering billions of dollars in duties that were collected under a statute the Court found unconstitutional for tariff purposes. With 53 million entries affected across more than 333,000 importers, this is the largest duty refund event in CBP history. This guide walks you through every step of the IEEPA duty recovery process - from understanding which entries qualify to filing claims through CBP's new CAPE system.

What Happened: The Supreme Court Decision

On February 20, 2026, the Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not grant the President authority to impose tariffs. The decision invalidated tariff orders that had been applied to imports from dozens of countries, covering everything from consumer electronics to industrial components. The ruling was immediate - there was no stay or phase-out period.

The trade community barely had time to process the news. Within hours of the decision, the White House reimposed tariffs under Section 122 of the Trade Act of 1974, a separate statutory authority that allows temporary tariff actions for balance-of-payments purposes. The rates and country coverage shifted, but the core message was clear: tariffs were not going away entirely.

What the Supreme Court decision did create, however, was a legal obligation for the government to refund all IEEPA duties that had been collected. CBP moved quickly. On February 24, 2026, the agency announced it would no longer apply or collect duties under the IEEPA tariff provisions and began building the infrastructure to process refunds at scale.

Key Dates for IEEPA RefundsFebruary 20, 2026: Supreme Court strikes down IEEPA tariffs. February 24, 2026: CBP stops collecting IEEPA duties and announces refund process. February 6, 2026: All CBP refunds now issued electronically via ACH - no more paper checks. March 2026: CAPE system 40-80% complete across four functional areas.

The CAPE System: How CBP Is Processing Refunds

CBP recognized early that a traditional entry-by-entry liquidation approach would be impractical for a refund event of this magnitude. Processing 53 million entries one at a time through manual review would take years and overwhelm both CBP and the brokerage community. The agency needed an automated solution.

That solution is CAPE - the Consolidated Administration and Processing of Entries system. Built within the existing ACE (Automated Commercial Environment) platform, CAPE replaces manual entry-by-entry liquidation with automated electronic processing designed to handle refunds at scale.

How CAPE Works

CAPE operates through a structured pipeline that automates the most time-consuming parts of the refund process:

• Claim Submission: Importers and brokers submit refund claims through the CAPE portal within ACE, using a standardized CSV format that identifies affected entries.
• Automated Validation: CAPE runs automated checks against each submission, verifying entry numbers, confirming that IEEPA provisions were applied, and flagging any inconsistencies.
• Duty Recomputation: The system removes IEEPA HTS provisions from each entry and recomputes the duty amount owed. This accounts for the fact that many entries involved multiple tariff programs - an entry might have both IEEPA and  duties, and only the IEEPA portion is refundable.
• Liquidation and Reliquidation: CAPE processes the liquidation (for unliquidated entries) or reliquidation (for entries already liquidated) and generates the refund amount.
• Electronic Disbursement: Refunds are issued via ACH directly to the importer's or broker's account on file. As of February 6, 2026, CBP no longer issues paper refund checks.

CAPE Development Status

As of March 2026, the CAPE system was between 40% and 80% complete across its four main functional areas: claim intake, validation, recomputation, and disbursement. CBP has been rolling out capabilities in phases, prioritizing the highest-volume entry types first. The agency has indicated that full CAPE functionality is expected to be operational well before the statutory deadline for filing refund claims.

Which Entries Are Eligible for IEEPA Refunds

Not every customs entry filed during the IEEPA tariff period qualifies for a refund. Understanding eligibility is critical for brokers managing client expectations and prioritizing their refund workload.

Eligible Entries

An entry is eligible for an IEEPA tariff refund if it meets all of the following criteria:

• The entry included one or more HTS line items subject to an IEEPA tariff provision (typically Chapter 99 subheadings linked to IEEPA executive orders).
• IEEPA duties were actually assessed and either paid or deposited.
• The entry has not already been adjusted to remove IEEPA duties through a prior protest or other administrative action.

The Scale of the Refund

MetricFigureTotal entries affected53 millionImporters affected333,000+Entries still unliquidated (as of March 4, 2026)20.1 millionEntries already liquidated (requiring reliquidation)~32.9 million

The distinction between unliquidated and already-liquidated entries matters. Unliquidated entries are simpler to process because CBP can adjust the duty calculation before final liquidation. Already-liquidated entries require formal reliquidation, which involves reopening a closed entry and recomputing duties - a more complex process, but one that CAPE is designed to handle automatically.

Important for BrokersEntries that involved multiple tariff programs require careful analysis. An entry with both IEEPA duties and Section 232 duties will only receive a refund for the IEEPA portion. The Section 232 tariff obligations remain in full effect. Make sure your refund calculations isolate the IEEPA component accurately.

How to File an IEEPA Refund Claim

Filing an IEEPA refund claim through CAPE is a structured process. While CBP has simplified it significantly compared to traditional protest-based refunds, brokers still need to follow specific steps to ensure claims are processed without delays.

Step 1: Identify Eligible Entries

Start by pulling a complete list of entries that included IEEPA tariff provisions. You will need to review every entry filed during the IEEPA tariff period and identify those with Chapter 99 HTS codes linked to IEEPA executive orders. For brokerages handling high volumes, this step alone can involve thousands of entries across dozens of importers. Automated tools like Cervo's tariff simulator can significantly speed up this identification process.

Step 2: Gather Entry Data

For each eligible entry, compile the following information:

• Entry number and entry date
• Importer of record number
• HTS line items that carried IEEPA provisions
• IEEPA duty amount assessed per line item
• Liquidation status (liquidated vs. unliquidated)
• Any prior protests or adjustments on the entry

Step 3: Format Your Submission

CAPE accepts claims in CSV format through the ACE portal. CBP has published a template with required fields and validation rules. Ensure your CSV file follows the exact format specification - submissions that fail validation will be rejected and require resubmission, adding days or weeks to your refund timeline.

Step 4: Submit Through the CAPE Portal

Log into ACE and navigate to the CAPE portal. Upload your CSV file and confirm the submission. CAPE will return an acknowledgment with a tracking number for each batch of entries submitted.

Step 5: Monitor and Respond

After submission, CAPE runs its automated validation checks. If any entries are flagged for discrepancies - mismatched entry numbers, incorrect duty amounts, or entries that have already been adjusted - CBP will send a notification through ACE. Brokers should monitor their ACE dashboard regularly and respond to any flags promptly to avoid processing delays.

Step 6: Receive Refunds via ACH

Once CAPE completes validation and recomputation, refunds are disbursed electronically via ACH. Confirm that your ACH information in ACE is current and accurate. Refunds will be deposited to the bank account on file for the filer - if you are filing on behalf of an importer, coordinate with them to ensure the correct account receives the funds.

Timeline: When to Expect Refunds

The IEEPA refund timeline depends on several factors, including the liquidation status of entries, the volume of claims CBP is processing, and how quickly the remaining CAPE functionality comes online.

Entry TypeExpected ProcessingNotesUnliquidated entries (20.1M)Faster - adjusted before liquidationNo reliquidation needed; CAPE removes IEEPA provisions and liquidates with corrected duty amountAlready-liquidated entries (~32.9M)Slower - requires formal reliquidationCAPE reopens the entry, recomputes, and processes refund; higher complexity per entryEntries with multiple tariff programsVariableRequires isolating IEEPA duty component from other programs (Section 232, Section 301, etc.)

CBP has not published a definitive timeline for completing all refunds, but industry analysts expect the bulk of processing for unliquidated entries to be completed within the first half of 2026. Reliquidation of already-liquidated entries will likely extend further, potentially into early 2027, depending on CAPE's processing capacity and the volume of claims received.

Do Not WaitEven though CAPE is still being built out, brokers should begin identifying and organizing their eligible entries now. When the system reaches full functionality, there will be a surge of claim submissions. Being prepared with clean, validated data will put your claims at the front of the processing queue.

How Cervo Identifies Refund-Eligible Entries

For brokerages processing hundreds or thousands of entries, manually reviewing each one for IEEPA eligibility is not realistic. That is exactly the problem Cervo's IEEPA refund reporting tool was built to solve.

Cervo's platform automatically scans your entry data and identifies every entry that included IEEPA tariff provisions. The tool cross-references HTS codes, Chapter 99 provisions, and duty amounts to produce a comprehensive report of refund-eligible entries organized by importer, entry date, and estimated refund amount.

What the Tool Provides

• Entry-level identification: Every entry with IEEPA duty exposure, including the specific HTS lines and duty amounts attributable to IEEPA.
• Importer summaries: Aggregated refund estimates per importer, making it easy to communicate expected recovery amounts to your clients.
• Liquidation status flagging: Each entry is flagged as liquidated or unliquidated, helping you prioritize your claim submissions.
• Export-ready data: Reports can be exported in formats compatible with CAPE's CSV submission requirements, reducing manual data entry and formatting errors.

Cervo's tariff simulator also lets you model how the removal of IEEPA duties and the addition of Section 122 tariffs affect landed costs for your importers going forward. This is especially valuable for clients who need to update their supply chain cost models to reflect the new tariff landscape.

If you are managing IEEPA refund claims across multiple importers, Cervo's entry automation tools can save hundreds of hours of manual data compilation. The platform pulls data directly from your entry records, eliminating the need to search through individual 7501s line by line.

What Replaced IEEPA: Section 122 Tariffs

While the Supreme Court eliminated IEEPA as a tariff authority, it did not eliminate tariffs. Within hours of the ruling, the White House invoked Section 122 of the Trade Act of 1974 to reimpose tariffs on many of the same product categories and trading partners that had been covered by IEEPA orders.

Section 122 authorizes the President to impose temporary tariffs of up to 15% for 150 days (extendable with Congressional approval) when necessary to address balance-of-payments deficits. The legal basis is different from IEEPA, and the rates and durations may not match what was in place under the IEEPA orders.

For customs brokers, the transition from IEEPA to Section 122 means:

• New HTS provisions: Section 122 tariffs use different Chapter 99 codes than IEEPA. Brokers need to update their tariff databases and classification workflows.
• Rate changes: Some products face different duty rates under Section 122 than they did under IEEPA. Use the  to model the impact.
• Duration limits: Unlike IEEPA tariffs, which had no built-in expiration, Section 122 tariffs are time-limited and may require Congressional action to extend.
• Stacking considerations: Section 122 tariffs can stack with other duty programs like  and Section 301, so total duty liability calculations need to account for all applicable programs.

We will publish a dedicated Section 122 tariff guide with full rate tables and country coverage details. For now, the key point is that IEEPA refunds and Section 122 compliance are two separate workstreams that brokers need to manage in parallel.

Bottom LineThe IEEPA refund process represents both a massive opportunity and a significant operational challenge for customs brokers. Billions of dollars in duties are eligible for recovery, but claiming those refunds requires accurate data, proper formatting, and timely submission. Brokerages that invest in automated identification and preparation tools will recover funds faster and with fewer errors than those relying on manual processes.

Recover IEEPA Duties Faster with Cervo

Cervo's IEEPA refund reporting tool automatically identifies every eligible entry and generates CAPE-ready claim data. Stop searching through entries manually - let automation do the work.

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