CBP Launches CAPE Refund System April 20 — How to Claim Your IEEPA Tariff Refund
The federal government owes US importers approximately $166 billion in IEEPA tariff refunds. Starting April 20, 2026, CBP launches the system that lets you actually claim them.
If your business paid IEEPA tariffs between February 2025 and February 2026, this is the most important operational news of the year. Here's what's happening, who qualifies for Phase 1, and what you need to do right now.
What Happened
On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that IEEPA (the International Emergency Economic Powers Act) does not authorize presidential tariffs. Chief Justice Roberts wrote bluntly: "IEEPA contains no reference to tariffs or duties."
That ruling invalidated billions of dollars of tariffs that had been collected from importers since early 2025. But it didn't create a refund mechanism. The administrative process to actually return the money has been working its way through the US Court of International Trade for the past two months.
On April 1, 2026, Senior Judge Richard K. Eaton of the CIT issued an order in Atmus Filtration, Inc. v. United States (Court No. 26-01259) confirming CBP is on track to launch the Consolidated Administration and Processing of Entries (CAPE) system by April 20, 2026. CBP's own court filings state the four refund-process components are 60-85% complete.
The Numbers
Per a March 31, 2026 declaration filed by Brandon Lord, CBP's Executive Director of the Trade Programs Directorate:
- $166 billion in IEEPA duties collected
- 53 million affected entries
- 333,000+ importers eligible for refunds
To put that in context: this is nearly double what CBP normally collects in regular duties in an entire year. It's the largest refund program in US customs history.
Who Qualifies for Phase 1
CAPE Phase 1 (launching April 20) covers approximately 63% of IEEPA-paid entries. Specifically:
| Entry Status | Phase 1 Eligible? |
|---|---|
| Unliquidated entries | Yes |
| Liquidated within last 80 days | Yes (preserves the 90-day voluntary reliquidation window under 19 U.S.C. 1501) |
| Final liquidations (90+ days) | No — deferred to later CAPE phases |
If your IEEPA entries are still unliquidated, or were liquidated within the last 80 days, you can file for refund through CAPE starting April 20.
If your entries are already in final liquidation status (the remaining ~37%), you'll need to wait for a later CAPE phase. The good news: in a major expansion, Judge Eaton's order extends refund eligibility to final-liquidation entries too — importers no longer need to file protests within the 180-day window to preserve refund rights.
Refund Timeline
Per CBP guidance, valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of your CAPE Declaration, absent compliance review issues.
That means if you file on April 20, you could see refund money in your account by mid-June to mid-July 2026.
What You Should Do Right Now
Don't wait until April 20. The brokers who file first will get refunds first. Here's the prep checklist:
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Identify your IEEPA entries. Pull every entry your business filed between approximately February 2025 and February 2026 where IEEPA-based tariffs were paid. Your customs broker should have these records.
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Check liquidation status. Determine which entries are unliquidated, which are within 80 days of liquidation, and which are in final liquidation. Phase 1 only covers the first two categories.
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Calculate your refund amount. Total the IEEPA duties paid on each eligible entry. This is what you'll be claiming.
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Contact your customs broker NOW. CAPE filings will go through your broker's ABI connection to CBP. They need to be ready to file on Day 1 with your specific entry data. Brokers who haven't talked to clients about CAPE prep are behind.
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Document everything. Keep entry summaries, payment confirmations, and IEEPA tariff calculations. CBP may request documentation to verify refund claims.
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Don't fall for scams. Real CAPE refunds happen through CBP's official ACE system via licensed customs brokers — not via third-party "refund recovery" services. Beware of anyone offering to "speed up" your refund for a fee.
What This Means for Customs Brokers
If you're a customs broker, your phone is about to ring constantly. Every importer client wants to know:
- "Am I eligible?"
- "How much will I get back?"
- "When will I see the money?"
Brokers who proactively reach out to clients before April 20 with "here's your IEEPA refund estimate and our timeline" will retain those clients and get referrals. Brokers who wait for clients to call will be playing catch-up on a $166 billion refund cycle.
Source
CBP IEEPA Duty Refunds Page | Supreme Court Opinion - Learning Resources v. Trump | Thompson Hine SmarTrade Analysis | Skadden Tariff Refund Memo
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