The Supreme Court ruled in February 2026 that IEEPA tariffs were unlawful. That means if your business paid import duties between February 2025 and February 2026, you are likely owed a refund.
The total amount owed across all affected importers is approximately $166 billion. The number of businesses affected is over 330,000.
The refunds are not automatic. You must take specific steps to receive them. And the window to act is right now.
Here is exactly what to do.
What happened — the short version
President Trump imposed tariffs on imports from most countries under the International Emergency Economic Powers Act in 2025. On February 20, 2026, the Supreme Court ruled 6-3 that IEEPA does not authorise tariffs. The tariffs were immediately struck down.
CBP stopped collecting IEEPA duties on February 24, 2026. The Court of International Trade then ordered CBP to refund all IEEPA tariffs paid. CBP is building an automated refund system called CAPE — Consolidated Administration and Processing of Entries — expected to open around April 20, 2026.
Step 1 — Register for ACH electronic refunds immediately
This is the most important step and the one most importers have not done.
As of February 6, 2026, CBP issues all refunds electronically only. Paper checks no longer exist. To receive any refund you must be registered for ACH payments through the CBP ACE portal.
Current data shows only approximately 6% of affected importers have completed this registration. If you are not registered, your refund cannot be issued regardless of how much you are owed.
Go to cbp.gov and create or log into your ACE Secure Data Portal account. Set up ACH banking information. This takes approximately 15 minutes and is free.
Do this today. Not after the CAPE portal opens. Now.
Step 2 — Compile your IEEPA entry data
To file a refund claim you will need a list of all import entry summaries from the period when IEEPA tariffs were in effect — roughly February 2025 to February 2026.
Your licensed customs broker holds this data. Contact them this week and ask for a CSV export of all entry summaries from this period that included IEEPA tariff payments.
Organise this data before the CAPE portal opens. When the portal launches you will need to upload a CSV list of entry summaries. If you do not have this data ready you will experience delays.
Step 3 — File your CAPE declaration as soon as the portal opens
CBP expects the CAPE claims portal to begin accepting declarations around April 20, 2026. Development is approximately 85% complete as of early April.
When the portal opens — file immediately. Do not wait to see how the process works. Early filers in historical CBP refund processes have received payments significantly faster than those who waited.
The process will work as follows. You upload your CSV list of entry summaries. CBP validates the data. CAPE automatically removes IEEPA duties from eligible entries. Entries go through liquidation. Refunds are issued electronically to your registered ACH account.
CBP estimates a 45-day window between claim submission and refund receipt.
Step 4 — Consider filing a protest for already-liquidated entries
If any of your IEEPA entries were already finally liquidated — meaning CBP had already closed the entry before the Supreme Court ruling — you may need to file a formal protest to keep the entry open for refund purposes.
Your customs broker can identify which entries fall into this category. Protests must be filed within 180 days of liquidation. Review your entry history now to identify any entries approaching this deadline.
How much are you owed
To estimate your IEEPA refund, identify all shipments imported between February 2025 and February 2026 and calculate the IEEPA component of duties paid on each entry. Your customs broker’s entry data will show the duty breakdown by tariff type.
The IEEPA tariff rates varied by country and product. For most Chinese-origin goods they were between 10% and 50% on top of existing duties. For goods from other countries they were typically 10% across the board.
What happens to your ongoing duty costs
The IEEPA refund covers tariffs already paid on past shipments. It does not affect your ongoing duty costs.
Your ongoing costs are now governed by the Section 122 surcharge of 15% on most imports — effective February 24, 2026 and due to expire July 24, 2026 — plus all existing Section 301 and Section 232 tariffs which remain in effect.
After July 24, 2026, the Section 122 surcharge will expire. New permanent Section 301 tariffs are expected to replace it. The tariff environment is not getting simpler.
Need help mapping your complete tariff exposure
The IEEPA refund is one piece of the picture. The larger question for most importers is what their ongoing duty costs look like under the current and upcoming tariff regime — and where the reductions are.
Domshark Raqam maps this for importers. We verify every HS code, calculate your exact annual duty exposure, and identify three specific cost reduction actions. Fixed price. 10 business days. Written report with debrief call.
Email saiju@domshark.co with the subject line ANALYSIS to get started.