Who qualifies for a tariff refund?

The three qualification tests

To file a refund under the April 2026 CAPE program, the importer must pass three tests:

1. IOR status — The entity must appear as the importer of record on CBP Form 7501 (Entry Summary). See Am I the importer of record? for how to verify.
2. Duty type — Only IEEPA-imposed tariffs are refundable under CAPE Phase 1. Section 301 (China), Section 232 (steel/aluminum), Section 201, and MFN rate duties remain in force and are not part of this refund pool.
3. Timing window — Entries must have been filed during the IEEPA period (2025 effective date through Feb 20, 2026 ruling). Entries paid outside this window fall under standard 19 USC 1514 protest rules.

Who is excluded

• Freight forwarders and customs brokers who advanced duty on behalf of a client. Only the IOR recovers the money.
• Sellers on marketplaces who did not hold IOR status. An Amazon FBA seller who shipped DDP with the supplier as IOR cannot claim the supplier's refund — see Amazon FBA seller refunds.
• Non-resident importers who do not hold a continuous bond or lack a US agent for service of process.
• Entries already liquidated more than 180 days prior to April 20, 2026 with no protest filed. That window closes permanently under 19 USC 1514(c)(3).

Entry status matters

CBP divides eligible entries into two buckets per CSMS guidance on the CAPE rollout:

• Unliquidated entries — Refunds process automatically once CAPE matches the entry to the IEEPA classification. No additional filing required beyond ACE portal registration.
• Liquidated entries within 180 days — A CF-19 protest must be filed before the window closes. Miss the window and the liquidation becomes final under 19 USC 1514.

Estimating your exposure

Pull the importer-specific ACE report for all entries filed in the IEEPA window, filter for HTSUS chapters that carried IEEPA add-on duty, and total the duty paid column. Our IEEPA refund calculator automates this using your ACE export. For a deeper walkthrough, read the IEEPA refund guide.

Why the filing deadline matters

The 180-day CF-19 clock runs from the date of liquidation, not the date of the Supreme Court ruling. An entry liquidated September 1, 2025 must be protested by late February 2026. An entry liquidated January 15, 2026 must be protested by mid-July 2026. Every week of delay pushes entries past the irreversible cutoff.

Calculate your tariff refund → /calculators/ieepa-refund

Related questions

Do I need a customs broker to file? A licensed broker is required for any customs business under 19 CFR 111. See can my customs broker file a refund.

Are Section 301 China tariffs included? No. CAPE covers only IEEPA duties. See Section 301 refund eligibility.

How long does processing take? CBP guidance indicates 60 to 90 days per entry once queued in CAPE. See tariff refund timing.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111.