IEEPA refunds cover duties paid on entries between April 5, 2025 and February 24, 2026. Eligibility depends on three things: the entry date (must fall in window), the duty mix on the entry (only the IEEPA-attributable portion is refundable, not Section 232 / 301 / MPF / HMF), and the entry’s liquidation status (unliquidated entries qualify; liquidated entries qualify if within the 180-day protest window or covered by the CIT refund order).
Many importers ask the wrong first question – “is my industry eligible?” – when the right first questions are about entry date, duty composition, and liquidation status. This matrix walks through the eligibility criteria in the order they actually matter, with examples by HS chapter so you can self-screen before filing or before engaging counsel.
Three gates: entry date, duty composition, liquidation status
Gate 1: entry date
IEEPA tariffs took effect April 5, 2025. They were replaced by Section 122 on February 24, 2026. Entries with an “Entry Date” between those two dates are within scope.
Entry date is the date CBP accepted the entry, not the date of the bill of lading or commercial invoice. It is the date stamped on CBP Form 7501 in box 2 (“Entry Date”).
Entries before April 5, 2025 are not eligible – IEEPA tariffs were not yet in force. Entries after February 24, 2026 paid Section 122, not IEEPA, so they are not eligible for the IEEPA refund process (though they may be eligible for a Section 122 refund if that surcharge is later struck down or expires without successor).
Gate 2: duty composition
The IEEPA refund process refunds only the IEEPA-attributable portion of the duty. If your entry stacked IEEPA + Section 232 + Section 301 + MFN + MPF + HMF, only the IEEPA portion is refundable.
On CBP Form 7501, the duty breakdown is in box 35-37. The IEEPA line typically shows as the global add-on rate (10% from April-November 2025, 15% from November 2025-February 2026 in some periods).
Where IEEPA stacked on top of an existing duty (e.g., Section 232 steel), only the IEEPA layer comes off. The Section 232 layer remains as paid.
Gate 3: liquidation status
Liquidation is when CBP finalizes the duty owed on an entry. Most entries liquidate within 314 days of entry. Until liquidation, an entry is “unliquidated” – your filing options are broad. After liquidation, you have 180 days to file a protest (19 U.S.C. § 1514).
Unliquidated entries are the easiest CAPE filings. Liquidated entries within 180 days of liquidation are also straightforward but file as a protest first if not already in scope of the CIT refund order.
Liquidated entries beyond 180 days are harder. They generally require either reliance on the CIT refund order in Atmus and the related cases, or a request for reliquidation under 19 U.S.C. § 1520.
Eligibility by HS chapter – the patterns we see
Eligibility is mostly about entry date and duty composition, not HS chapter – but the duty composition correlates strongly with HS chapter, so we organize the most common patterns below.
- Chapters 50-63 (textiles, apparel) – heavily IEEPA-affected. Many entries paid the full IEEPA add-on with no offsetting Section 232. Refundable portion is typically large.
- Chapters 84-85 (machinery, electronics) – mixed. China-origin goods often have stacked Section 301 + IEEPA, where only the IEEPA portion is refundable. Non-China origin saw IEEPA only and is fully refundable.
- Chapters 72-83 (steel, aluminum, fabricated metal) – Section 232 dominates. IEEPA stacked on top in some configurations. The IEEPA portion is refundable; the Section 232 layer stays.
- Chapters 28-39 (chemicals, plastics) – heavy IEEPA exposure. Most entries had no Section 232 or 301 overlay. Largest typical recoverable percentages.
- Chapter 87 (vehicles and parts) – complex. Section 232 auto rules and IEEPA interacted differently for different HS subheadings. Worth a manual review.
- Chapters 1-24 (agricultural, food) – depends heavily on country of origin and FTA status. USMCA-qualifying entries were not subject to IEEPA in many configurations; non-USMCA were.
Special cases worth a closer look
Drawback claims interaction
If you filed duty drawback on an entry that also carried IEEPA duty, the drawback claim may have already recovered the IEEPA portion. Check your drawback ruling before filing through CAPE; double recovery is grounds for denial and possible enforcement.
FTZ admissions
Goods admitted to a Foreign Trade Zone before April 5, 2025 and entered for consumption after that date generally paid IEEPA on the consumption entry. The consumption entry date governs eligibility. Check your CBP Form 214 and matching consumption entry summary.
Reconciliation entries
Importers using ACE reconciliation may have IEEPA duties on the reconciliation true-up rather than the original entry. Refund eligibility flows through the reconciliation entry, not the underlying flagged entry.
Protests already filed
If you filed a protest on an IEEPA entry before the SCOTUS ruling, the protest may roll into the CAPE refund automatically – or may need to be withdrawn and re-filed through CAPE depending on protest status. Check status with your broker.
Quick self-screen: is my filing worth pursuing?
A practical filter we use with new clients:
- Estimate your IEEPA-attributable duty paid in the April 2025 – February 2026 window. Below $5,000 – self-file via CAPE; the consultant fee will exceed the recovery.
- Between $5,000 and $50,000 – self-file CAPE if your documentation is clean; consider a consultant if your entry mix is complex.
- Between $50,000 and $250,000 – consultant or trade attorney is generally cost-justified, particularly if Section 232 or 301 stacking is present.
- Above $250,000 – engage counsel. Filings at this scale see CBP scrutiny and benefit from staged filings, dedicated attention, and litigation-ready documentation.
Frequently asked questions
How do I know if I paid IEEPA duty specifically?
Check CBP Form 7501 (entry summary) box 35-37 for the duty breakdown. The IEEPA line shows the IEEPA add-on rate (typically 10% or 15% depending on entry date) applied to the customs value. Your customs broker can pull the breakdown for any entry in their records.
I imported under USMCA – am I eligible for any refund?
USMCA-qualifying goods were largely exempt from IEEPA in the first place, so there may be little to recover. But check entry dates around April-May 2025 carefully – the USMCA exemption was implemented unevenly in the early weeks of the IEEPA tariff. Entries from that period sometimes paid IEEPA in error.
What if I no longer have my entry summaries?
Your customs broker has them on file (regulatory retention is 5 years). For self-filed entries, log into ACE Portal and pull entry history under your importer of record number.
Are warehouse withdrawals from a bonded warehouse eligible?
Yes, if the withdrawal-for-consumption entry date falls in the April 5, 2025 – February 24, 2026 window. Warehouse admissions before April 5, 2025 do not disqualify; the consumption entry date is what matters.
Can I claim a refund for goods I have already exported?
Drawback territory, not CAPE. If you exported the goods after paying IEEPA duty, file a drawback claim instead. Drawback recovers up to 99% of duties; CAPE recovers the IEEPA portion. Choose the larger of the two; do not file both for the same entry.
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