IEEPA Refund Guide - Peacock Tariff Consulting

International Emergency Economic Powers Act (IEEPA): Refund Guide

Recovering Your IEEPA Tariff Refund

The Supreme Court ruled IEEPA tariffs were unlawful. CBP has been ordered to refund over $166 billion. But eligibility, timing, and who actually receives the money all depend on details you control, and the window to act is already closing on some entries.

CURRENT STATUS

The refund window is open. CBP built a dedicated system called CAPE inside the ACE Secure Data Portal to process IEEPA refund claims. Filing opened April 20, 2026. In its first six weeks, CBP processed refunds on nearly 8.5 million entries, but also reported nearly 50,000 rejected claims in the first month alone. The government has also appealed the universal refund order, which puts Phase 3 entries at risk for importers who have not filed a protective action.

We handle the full filing lifecycle, from entry inventory to payout, for companies that do not have a full-time trade compliance team.

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How The Refund Works

On February 20, 2026, the U.S. Supreme Court ruled 6-3 that IEEPA does not give the President authority to impose tariffs. The U.S. Court of International Trade then ordered the federal government to refund IEEPA duties to importers of record. Every dollar collected since the tariffs took effect is now potentially refundable, if the claim is filed correctly and on time. For a full breakdown of the case and its legal implications, see our IEEPA background summary here.

CBP built a dedicated tool to process these refunds called CAPE (Consolidated Administration and Processing of Entries), which lives inside the ACE Secure Data Portal. Refunds run through four automated stages:

01 Claim Portal

You or your filing representative upload a CSV listing the entry summaries you are claiming. The file is screened for formatting, filer identity, and to confirm each entry carries at least one IEEPA Chapter 99 HTS number.

02 Mass Processing

CAPE strips the IEEPA Chapter 99 lines from each accepted entry and recalculates duties as if the IEEPA charge had never been assessed.

03 Review and Reliquidation

CAPE schedules each entry to liquidate or reliquidate, opens a window for any manual CBP review, and calculates statutory interest owed.

04 Electronic Disbursement

Refunds are paid by ACH, consolidated by liquidation date and importer of record, or by whatever third party is named on CBP Form 4811.

Timing note: CBP has indicated accepted submissions generally take 45 to 90 days from submission to payment, though timing varies by entry type and review volume.

Which Phase Are Your Entries In?

CBP is rolling out CAPE in phases based on how far along your entries are in the liquidation cycle. Knowing your phase determines when, and whether, you will be paid.

PHASE

STATUS

What It Covers

Phase 1

Active

Unliquidated entries and entries liquidated within roughly the last 80 days. Refunds are being processed and paid now.

Phase 2

Active

Reconciliation (Type 09) entries and certain AD/CVD-affected entries that meet timing rules. Combined coverage is roughly $130 billion of the $166 billion total.

Phase 3

Targeted late
July 2026

Finally liquidated entries, liquidated more than roughly 80 days before the refund window opened. Under the government’s current position, these will be refunded only to importers who filed a lawsuit at the CIT.

Don’t assume Phase 2 catches everything. Reconciliation entries filed in the earliest months of the IEEPA period may have already liquidated more than 80 days ago and fall outside Phase 2’s window. Confirm eligibility entry-by-entry if you have meaningful reconciliation or AD/CVD exposure.

Four Mistakes That Cost Importers Their Refund

Most rejected and misdirected refunds come from the same avoidable errors.

Assuming your customs broker will handle it

Brokers are transaction-focused. Most are not set up for multi-entry refund strategy or preservation of rights across a full portfolio of entries.

Missing the 180-day protest window

Liquidation is automatic 314 days after entry unless extended. The clock is already running on many 2025 entries. A missed protest window cannot be reopened.

Letting a stale Form 4811 redirect your refund

CBP Form 4811 lets an importer designate a third party to receive refunds on their behalf. Many importers signed 4811 designations years ago and forgot about them. CAPE pays whoever is designated on the form. If a broker or carrier like FedEx is still listed, your refund can be deposited into their account instead of yours, even when they have no claim to it. Recovering misdirected funds from a third party is far harder than fixing the designation up front.

Filing without reconciling your classifications

If CBP re-examines an entry and the HTS code is wrong, what started as a refund claim can turn into an assessment. Classification accuracy is not optional.

How Peacock Tariff Consulting Helps

Recovering an IEEPA refund is part data exercise, part compliance discipline, and part legal strategy. We work directly with importers to assess exposure, correct classifications, and recover duties. No generalist approach. Every engagement is tailored to your entry portfolio.

Our engagement covers the full filing lifecycle:

✅ Duty exposure inventory across all IEEPA-affected entries

✅ Liquidation-status mapping with deadline tracking

✅ PSC and protest preservation to keep your refund rights alive

✅ Review and correction of Form 4811 designations and ACH refund enrollment before disbursement

✅ CAPE CSV preparation, validation, and submission through the ACE portal

✅ Coordination with your customs broker, tax team, and finance

✅ Refund tracking through to payout

✅ Mapping entries across Phases 1, 2, and 3 with guidance on protective CIT filing for Phase 3 exposure

No long-term contracts required. Typical engagements run from inventory through filing in 4 to 8 weeks depending on volume.

Frequently Asked Questions

What did the Supreme Court rule about IEEPA tariffs?

On February 20, 2026, the U.S. Supreme Court ruled 6-3 that the International Emergency Economic Powers Act does not give the President the authority to impose tariffs. IEEPA allows the President to “regulate” importation during a declared national emergency, but regulating is not the same as taxing. That distinction is what unlocked the refund.

How much in IEEPA tariffs could be refunded?

CBP has collected more than $166 billion in IEEPA tariffs since 2025. The total refund opportunity is significant, though individual recovery depends on your entry dates, liquidation status, and whether PSCs or protests were filed in time.

What is CAPE and how does it work?

CAPE (Consolidated Administration and Processing of Entries) is the dedicated refund mechanism CBP built inside the ACE Secure Data Portal. It is not a protest. It is an administrative refund process for duties CBP has been ordered to return. You upload a CSV of your IEEPA-affected entries, CAPE strips the Chapter 99 charges, reliquidates each entry, and disburses the refund by ACH.

What is the Form 4811 issue?

CBP Form 4811 is a Special Address Notification that designates a third party, often a customs broker or carrier, to receive refunds on your behalf. Many importers signed these designations years ago and never updated them. CAPE pays whoever is currently designated on the form. If an old broker designation is still active, your refund can be sent to them instead of you. We review and correct these designations before any filing is submitted.

Do I need a lawyer to file?

No. CAPE is an administrative refund process, not litigation. However, for Phase 3 entries (those liquidated more than roughly 80 days before April 20, 2026), a protective filing at the Court of International Trade may be necessary to preserve your rights if the government’s appeal is successful. We advise on this as part of our engagement and can coordinate with trade counsel where needed.

How long does it take to receive a refund?

CBP has indicated accepted submissions generally take 45 to 90 days from submission to payment, though timing varies by entry type and review volume.

Can I file this myself?

Some importers can, particularly if they have a small number of entries, clean ACE records, and an in-house compliance team. The process becomes significantly more complex with larger entry volumes, mixed entry types, AD/CVD exposure, or reconciliation entries. CBP reported nearly 50,000 rejected claims in CAPE’s first month, most from avoidable formatting and designation errors.

Ready to Recover What You’re Owed?

The refund window is open and entries are being processed now. The sooner you inventory your exposure, the more options you have. Schedule your free refund assessment today.