Section 1
What Happened: SCOTUS Struck Down IEEPA Tariffs
On February 20, 2026, the Supreme Court of the United States ruled 6-3 in Learning Resources, Inc. v. Trump that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded the President's statutory authority. The Court held that IEEPA does not authorize the imposition of import duties, which are constitutionally reserved to Congress under Article I, Section 8.
The ruling invalidated all tariffs collected under IEEPA authority from their initial imposition in April 2025 through the date of the decision. This means every dollar collected under these tariffs is legally owed back to the importers who paid them.
Key Ruling Details
- Case: Learning Resources, Inc. v. Trump, 602 U.S. ___ (2026)
- Decision: 6-3 ruling; IEEPA does not authorize import tariffs
- Date: February 20, 2026
- Effect: All IEEPA tariffs collected April 2025 – Feb 20, 2026 must be refunded
- Tariff authority affected: HTS Chapter 99 entries imposed under IEEPA
Within weeks of the ruling, U.S. Customs and Border Protection (CBP) announced it would establish an automated refund process rather than requiring individual protests for each affected entry. The result is the CAPE portal.
Section 2
What You're Owed: The Scale of the Refund
The IEEPA tariff refund is the largest mass duty refund event in U.S. customs history. Here are the numbers:
$166B
Total duties to be refunded
~$23M
Interest accruing per day
The total refund pool of approximately $166 billion covers duties collected across 53 million entry summary lines from 333,000 individual importers of record. Statutory interest under 19 USC 1505(b) accrues at approximately $23 million per day across all claims, which means every day you delay filing costs you money.
Refund amounts vary enormously by importer. Large retailers and manufacturers who sourced heavily from countries targeted by IEEPA tariffs may be owed tens of millions. Small importers with a handful of entries may be owed thousands. Regardless of size, the money is yours and the process to claim it is the same.
Interest Is Accruing Now
Statutory interest under 19 USC 1505(b) runs from the date duties were deposited. CBP is required to pay interest on all refunded amounts. The longer it takes to process your claim, the more interest accrues — but the sooner you file, the sooner you get paid.
Section 3
The CAPE Portal: CBP's Automated Refund System
CAPE (CBP Automated Protest and Entry-level refund system) is the web-based portal CBP built specifically to process the IEEPA refund at scale. Rather than forcing 333,000 importers to each file formal protests under 19 USC 1514, CBP created CAPE to streamline the process into a declaration-based system.
The portal was announced via CBP CSMS #68315804 on April 10, 2026, with full details available at cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds.
Phase 1
Unliquidated & Non-Final Entries
Covers entries that have not yet been liquidated or are still within the protest period. Approximately 63% of all affected entries fall into this category.
Launches April 20, 2026
Phase 2
Liquidated & Final Entries
Will cover entries that have been liquidated and are past the normal protest window. Requires additional legal framework from CBP.
Date TBD by CBP
What "Unliquidated" Means for Your Entries
An entry is "unliquidated" if CBP has not yet made a final determination on the duties owed. Given the volume of IEEPA entries and normal CBP processing timelines, the majority of entries from 2025-2026 have not yet been liquidated — which is why Phase 1 captures roughly 63% of all affected entries.
You can check the liquidation status of your entries through the ACE (Automated Commercial Environment) portal or by contacting your customs broker.
Don't Wait for Phase 2
If you have entries in both categories, file your Phase 1 claims immediately on April 20. Waiting does not help. Phase 2 will be a separate process and filing Phase 1 now does not affect your Phase 2 eligibility.
Section 4
Eligibility: Do You Qualify for a Refund?
You qualify for an IEEPA tariff refund if you meet all of the following criteria:
| Requirement |
Details |
| You are the importer of record |
Your name or company appears as the importer of record on CBP Form 7501 entry summaries |
| You paid IEEPA duties |
Your entries include duty lines under HTS Chapter 99 subheadings imposed under IEEPA authority |
| Entry period: Apr 2025 – Feb 20, 2026 |
The tariffs were in effect from April 2025 through the SCOTUS ruling date of February 20, 2026 |
| Phase 1: Entries are unliquidated or non-final |
For the April 20 launch, only entries that have not yet been liquidated or are still within the protest window qualify |
How to Check If You Paid IEEPA Duties
Look at your CBP Form 7501 entry summaries. IEEPA tariffs were collected under HTS Chapter 99 subheadings that specifically reference IEEPA authority. If you see Chapter 99 duty lines on your entry summaries for goods entered between April 2025 and February 20, 2026, you almost certainly qualify.
If you use a customs broker, ask them to pull a report of all entries with Chapter 99 IEEPA-related duty lines for the affected period. Most brokers are already preparing these reports for their clients in anticipation of the CAPE launch.
Section 5
How to File: Step-by-Step Instructions
Follow these steps to file your IEEPA refund claim through the CAPE portal when it opens on April 20, 2026:
-
Register at cbp.gov/cape. Starting April 20, navigate to the CAPE portal at
cbp.gov/cape. You will need your ACE portal credentials or importer of record number to register. If you do not have ACE access, your customs broker can file on your behalf with proper power of attorney.
-
Pull your CBP Form 7501 entry summaries. Gather all entry summaries for goods entered between April 2025 and February 20, 2026. You can access these through ACE or request them from your customs broker. Focus on entries that contain Chapter 99 IEEPA-related duty lines.
-
Identify Chapter 99 IEEPA duty lines. On each entry summary, look for the HTS subheadings in Chapter 99 that were imposed under IEEPA authority. These are the specific duty lines eligible for refund. Note the duty amounts paid on each line — this is what you will be claiming back.
-
Submit your declaration on CAPE. The CAPE portal uses a declaration-based process. You will identify the affected entries, confirm the IEEPA duty amounts, and submit your claim. CBP will cross-reference your declaration against its own records to validate the amounts.
-
Track your claim status. After filing, CAPE will provide a claim reference number. CBP has not yet published expected processing timelines, but given the scale (53M entry lines), earlier filers will likely be processed first. Monitor CBP CSMS messages for processing updates.
Preparation Checklist (Do This Now)
- Confirm your ACE portal access credentials work
- Download all CBP Form 7501 entry summaries for April 2025 – Feb 2026
- Identify and tally all Chapter 99 IEEPA duty line amounts
- Confirm your importer of record number
- Contact your customs broker to coordinate filing strategy
- Check liquidation status of your entries (Phase 1 = unliquidated only)
Section 6
How to Estimate Your Refund
Your IEEPA refund consists of two components: the duties you paid, plus statutory interest.
Refund Estimate Formula
Estimated Refund = Total IEEPA Duties Paid × 1.0 + Interest
Where:
• Total IEEPA Duties Paid = Sum of all Chapter 99 IEEPA duty amounts from your CBP Form 7501 entry summaries
• Interest = Accrues under 19 USC 1505(b) from the date each duty was deposited through the date of refund
• Interest rate is set quarterly by CBP based on the federal short-term rate
Example Calculation
| Entry Date |
IEEPA Duty Paid |
Days Since Payment |
Est. Interest |
Est. Refund |
| Jun 2025 |
$50,000 |
~300 days |
~$2,100 |
~$52,100 |
| Sep 2025 |
$120,000 |
~210 days |
~$3,500 |
~$123,500 |
| Jan 2026 |
$80,000 |
~90 days |
~$1,000 |
~$81,000 |
Interest estimates above are illustrative only. Actual interest rates are set quarterly by CBP and applied on a per-entry basis. Your customs broker can provide a precise calculation.
Track Your Estimates
Use our IEEPA Refund Analyzer to get a detailed estimate based on your specific entry data, or run a classification check to confirm which of your HTS codes fall under the affected Chapter 99 subheadings.
Section 7
Frequently Asked Questions
Who qualifies for an IEEPA tariff refund through the CAPE portal?
Any importer of record who paid duties on goods entered under IEEPA Chapter 99 HTS subheadings between April 2025 and February 20, 2026 is eligible. This includes approximately 333,000 importers who paid duties on an estimated 53 million entry summary lines. Both individual entries and entries filed through customs brokers qualify. The importer of record listed on CBP Form 7501 is the party entitled to the refund.
How much is my IEEPA tariff refund worth?
Your refund equals the total IEEPA duties you paid (the Chapter 99 duty lines on your entry summaries) plus statutory interest. The total refund pool is approximately $166 billion across all importers. Interest accrues from the date of payment at the rate set by 19 USC 1505(b). To estimate your individual refund, sum all Chapter 99 IEEPA duty amounts from your CBP Form 7501 entry summaries filed between April 2025 and February 20, 2026.
What is CAPE Phase 1 and when does it launch?
CAPE (CBP Automated Protest and Entry-level refund system) Phase 1 launches April 20, 2026, at cbp.gov/cape. Phase 1 covers unliquidated and non-final entries, which represent approximately 63% of all affected entries. Importers with these entry types can submit refund declarations immediately upon launch. Phase 2, which will cover liquidated and final entries, has not yet been scheduled by CBP.
What documents do I need to file an IEEPA refund claim?
You need: (1) Your CBP Form 7501 entry summaries for the affected period (April 2025 through February 20, 2026), (2) identification of the specific Chapter 99 IEEPA duty lines on each entry, (3) your importer of record number, and (4) your ACE portal credentials or broker authorization. CBP recommends pulling all entry summaries in advance and identifying IEEPA-specific duty amounts before the portal opens.
What if my entries have already been liquidated?
CAPE Phase 1 (launching April 20) only covers unliquidated and non-final entries, which represent approximately 63% of total affected entries. Liquidated and final entries will be addressed in Phase 2, which CBP has not yet scheduled. If your entries have been liquidated, you should still prepare your documentation now. Monitor CBP CSMS messages and the IEEPA duty refunds page at cbp.gov for Phase 2 announcements.