If your business imported goods from China, Canada, Mexico, or any of the other countries affected by IEEPA tariffs between early 2025 and early 2026, you may be owed a significant refund — and the federal government is now actively processing claims.

Here is what happened, what it means for your business, and what you need to do right now.

What the Supreme Court Ruled

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act does not authorize the president to impose sweeping tariffs. The Court held that when Congress passed IEEPA in 1977, it never intended to grant the executive branch that kind of broad trade authority — and that the tariffs imposed in 2025 violated the constitutional separation of powers.

Within weeks of the ruling, the Court of International Trade ordered U.S. Customs and Border Protection to refund the unlawfully collected duties to all affected importers. CBP responded by launching the CAPE portal — Customs Automated Processing Environment — on April 20, 2026.

How Much Money Are We Talking About?

CBP estimates that $166 billion or more in IEEPA tariff surcharges was collected from U.S. importers between early 2025 and early 2026. More than 330,000 businesses across every import category are potentially affected.

The actual refund for any given business depends on import volume, countries of origin, and the specific tariff rates applied to their goods. IEEPA tariff rates ranged from 10% on some categories to over 145% on Chinese-origin goods at the peak of the tariff escalation.

A business that imported $1 million in goods from China when the 145% tariff rate was in effect could be owed more than $1.4 million in refunds. Even businesses with more modest import volumes may have six-figure recovery opportunities.

The CAPE Portal — What It Is and How It Works

The CAPE portal is a module within CBP’s existing ACE (Automated Commercial Environment) platform. It accepts structured refund claims from importers of record — the businesses legally responsible for the customs entries at the time of import.

Phase 1 covers entries finalized on or before January 30, 2026 — the most straightforward category of claims. Claims are filed as CSV-formatted declarations that reference the original CBP Form 7501 entry data. The portal accepts up to 9,999 entry lines per declaration.

Once claims are approved, CBP reliquidates the affected entries and issues refunds via ACH direct deposit — typically within 60 to 90 days of approval.

Who Qualifies for a Refund

To qualify for an IEEPA tariff refund through the CAPE portal, all of the following generally must apply:

  • You imported goods into the U.S. between February 2025 and February 2026
  • You paid IEEPA tariff surcharges on your imports — these appear as HTS Chapter 99 codes with the prefix 9903.01.xx on your customs entries
  • You are listed as the Importer of Record on CBP Form 7501 (Box 26)
  • Your ACE portal account has ACH banking configured for refund disbursement
  • Your entries are unliquidated, or were liquidated within the last 80 days

Industries With the Highest Recovery Potential

IEEPA tariffs affected importers across virtually every sector. The industries with the most significant refund exposure include:

  • Electronics and technology hardware — among the highest tariff rates applied to Chinese-origin goods
  • Apparel, textiles, and footwear — high-volume imports from China and other affected countries
  • Industrial equipment and machinery — large per-unit values amplify aggregate recovery amounts
  • Consumer goods and housewares — broad category with substantial import exposure
  • Auto parts and components — significant China-origin supply chains
  • Furniture and home goods — major China-origin import category
  • Amazon FBA and e-commerce sellers — many imported inventory directly as the importer of record
  • Food and beverage — affected by Canada and Mexico tariffs in addition to China

Why Timing Matters

Interest on unliquidated duty refunds accrues at a statutory rate — estimated at roughly $22 million per day across all affected importers. That interest accumulates in your favor, but only for entries that are actually filed.

Phase 1 covers the cleanest, most straightforward entries. Future phases will cover protested entries, antidumping and countervailing duty interactions, and drawback claims — all of which carry additional documentation complexity and potentially longer processing timelines.

Businesses that file in Phase 1 get the fastest, most predictable refund process. Businesses that delay risk additional procedural complications as the program evolves.

How to Check If Your Business Qualifies

A free qualification screen takes about three minutes. You will answer a few questions about your import history, countries of origin, and import volumes — and a recovery specialist will review your situation and estimate your refund potential.

Most recovery specialists work on a contingency fee structure — no recovery, no fee. That means there is no cost to pursuing a claim and no financial risk to the business if the refund does not materialize.

Frequently Asked Questions

What are IEEPA tariffs?

IEEPA tariffs were duties imposed by the Trump administration in 2025 under the International Emergency Economic Powers Act, a 1977 law giving the president authority to regulate foreign commerce during a declared national emergency. Tariff rates varied by country and product category, ranging from 10% to over 145% on Chinese-origin goods.

What did the Supreme Court rule?

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that IEEPA does not authorize sweeping tariffs. The Court held that Congress never granted the president that power when it passed IEEPA, and that the tariffs violated the separation of powers. CBP was subsequently ordered to refund the collected duties.

What is the CAPE portal?

The CAPE (Customs Automated Processing Environment) portal is a module within CBP’s ACE platform that allows importers of record to file structured IEEPA tariff refund claims. It launched April 20, 2026. Phase 1 covers entries finalized on or before January 30, 2026.

How long does the refund process take?

CBP estimates a typical refund window of 60 to 90 days after claim approval. Interest on unliquidated entries accrues in the importer’s favor during this period at a statutory rate.

Do I need a customs broker to file?

Businesses can file directly if they have ACE portal access, a licensed customs broker, and the internal resources to compile and format the required documentation. Many importers choose to work with a recovery specialist on a contingency basis, particularly if claim volume is high or internal customs expertise is limited.

Are Section 301 tariffs also eligible for refunds?

Section 301 tariffs — imposed under a separate legal authority — are generally not covered by this IEEPA refund program. Only tariffs specifically imposed under IEEPA authority and identified by HTS Chapter 99 prefix 9903.01.xx are eligible under Phase 1 of the CAPE program.