IEEPA refund eligibility depends on entry type. Standard consumption entries (Type 01) are most straightforward. Warehouse withdrawals (Type 03) follow consumption entry date. FTZ admissions in Privileged Foreign status follow consumption entry date. Drawback claims may have already recovered IEEPA – check before filing CAPE. Post-summary corrections and protests have specific interaction patterns.
CAPE filings handle the most common case – consumption entries paid IEEPA, eligible for refund. But importers regularly run other entry types: warehouses, FTZs, drawbacks, reconciliations. Each has specific eligibility rules.
Type 01 – consumption entries
Standard consumption entries on or after April 5, 2025 and before February 24, 2026 are CAPE-eligible. The IEEPA-attributable portion is refundable; Section 232/301 portions are not.
Type 03 – warehouse withdrawal entries
Warehouse withdrawals follow the withdrawal date for IEEPA eligibility. Goods admitted to bonded warehouse before April 5, 2025 and withdrawn after that date paid IEEPA on the withdrawal entry; eligible for refund. Goods admitted and withdrawn before April 5 paid no IEEPA – no refund.
FTZ status types – privileged vs non-privileged
FTZ goods in Privileged Foreign (PF) status had duty rates locked at admission. Goods admitted before April 5, 2025 in PF status do not pay IEEPA on consumption entry. Non-Privileged Foreign (NPF) status follows consumption-entry-date rates; admitted before April 5, withdrawn after, pays IEEPA on withdrawal – eligible for refund.
Drawback interaction
If you filed manufacturing or unused merchandise drawback on an IEEPA entry, the drawback may have already recovered the IEEPA portion. Check your drawback ruling before filing CAPE; double recovery is grounds for denial and possible enforcement.
Post-summary correction interaction
PSCs that increased or decreased duty during the IEEPA window can complicate the refund calculation. The IEEPA portion as ultimately liquidated is the refundable amount. PSCs themselves are not separately refundable.
Protest interaction
If a protest was filed on an IEEPA entry before the SCOTUS ruling, the protest may roll into CAPE or may need to be withdrawn and re-filed. Check status with broker.
Frequently asked questions
Which entry type is easiest to refund?
Standard Type 01 consumption entries. The CAPE template is built for these.
Can I file CAPE on a warehouse withdrawal?
Yes – if the withdrawal entry date falls in the IEEPA window. The admission date does not matter; the withdrawal entry date governs.
Do FTZ goods ever benefit from CAPE?
Yes – NPF goods withdrawn during the IEEPA window. PF goods admitted before April 5, 2025 do not pay IEEPA, so no refund.
What if I already filed drawback on these entries?
Check the drawback ruling carefully. Drawback may have recovered IEEPA already; CAPE filing on the same entry would be double recovery.
Can I file CAPE on a reconciliation entry?
Yes – the reconciliation entry date governs. If reconciliation was filed during or after the IEEPA window, eligible IEEPA portions are refundable.
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