If you import goods into the United States, there's a reasonable chance you've overpaid duties under the IEEPA tariff program — and you may be eligible for a refund. But CBP isn't going to tell you that. The refund process is not automatic, and the window to act is not unlimited.
This guide covers what the IEEPA tariffs are, how the rollbacks created refund opportunities, who's eligible, how to file, and what to watch out for.
What Are IEEPA Tariffs?
IEEPA stands for the International Emergency Economic Powers Act. Beginning in 2025, the administration used IEEPA authority to impose reciprocal tariffs on imports from a broad range of countries. These tariffs were applied on top of existing duty rates — meaning an importer could owe the base MFN duty, plus Section 301, plus Section 232, plus IEEPA, all on the same entry line.
The rates varied by country and changed multiple times as executive orders were issued, paused, modified, and reinstated. That constant movement is what created the refund opportunity.
How Did the Rollbacks Create Refund Eligibility?
When IEEPA tariff rates were reduced or paused for certain countries or time periods, entries that had already been liquidated at the higher rate became potentially overpaid. CBP collected duties at the rate in effect at the time of entry — but if that rate was later reduced retroactively or determined to have been applied incorrectly, the difference is refundable.
The key word is "potentially." Not every entry qualifies. The refund depends on the specific HTS code, the country of origin, the entry date, and whether the duty paid was actually IEEPA or something else entirely.
The $166 Billion Problem
Estimates suggest approximately $166 billion in IEEPA-related duties may be refundable. As of mid-2026, roughly 275,000 importers have not yet registered for the CAPE portal or taken any action to screen their entries. Many don't even know the refund opportunity exists.
The importers who are most likely to be owed money are small to mid-sized companies that import regularly but don't have in-house trade compliance staff. They rely on their customs broker to file entries correctly, and they don't typically review their 7501s line by line.
What Is the CAPE Portal?
CAPE stands for the Customs Automated Protest and Entry system. It's the CBP portal through which refund claims are filed. To file for an IEEPA refund, you need to register for a CAPE account, prepare your documentation, and submit a claim that identifies the specific entries and line items where IEEPA duties were overpaid.
CAPE is not intuitive, and the filing requirements are specific. Getting the wrong entry number format, misidentifying the tariff program, or submitting incomplete documentation can delay or kill a claim.
Who Is Eligible?
You may be eligible for an IEEPA refund if all of the following are true:
You imported goods into the United States during a period when IEEPA tariffs were in effect. The duties you paid included an IEEPA component (not Section 232, not Section 301, not AD/CVD). The IEEPA rate that applied to your entry was later reduced, paused, or rolled back for the relevant country and HTS code. And your entries have not already been refunded or protested for the same issue.
The Most Common Mistake: Conflating IEEPA with 232 and 301
This is where most free calculators and even some brokers get it wrong. IEEPA tariffs, Section 232 tariffs, and Section 301 tariffs are three separate programs with different legal authorities, different rates, and different refund mechanisms.
Section 232 tariffs apply to steel and aluminum products (and certain derivatives) based on national security authority. Section 301 tariffs apply primarily to goods from China based on trade practices findings. IEEPA tariffs are the reciprocal tariffs imposed under emergency economic powers.
If your entry includes a Section 232 duty and you file for an IEEPA refund on that line, your claim will be rejected. Worse, you may not realize the error until months later when CBP responds.
Separating these programs requires looking at the Chapter 99 codes on your 7501, understanding which program each code belongs to, and confirming that the duty you're claiming was actually IEEPA. This is not something a simple calculator can do reliably.
What's NOT Refundable
Not every duty qualifies for an IEEPA refund. The following are generally not refundable through the IEEPA/CAPE process:
Section 232 duties on steel, aluminum, and derivative products. Section 301 duties on goods from China. Antidumping and countervailing duties (AD/CVD). Section 122 balance-of-payments duties. And base MFN duties — even if they seem high, they're not part of any special tariff program.
If you're not sure which duties on your entries are IEEPA and which are something else, that's exactly the kind of analysis a licensed customs broker can help with.
How to Screen Your Entries
There are two paths: do it yourself, or have a broker do it for you.
The self-service option is the IEEPA Refund Screener — a 9-tab Excel workbook that cross-references your entry data against IEEPA rate tables, country timelines, and Chapter 99 codes. You paste in your HTS codes, duty amounts, and countries of origin, and it flags which lines are refund-eligible and estimates recovery amounts. It costs $29 and runs entirely on your computer.
The full-service option is an IEEPA Refund Screening engagement. I review your complete entry portfolio, separate IEEPA from 232/301/AD-CVD, identify every refundable line, prepare the documentation, and handle the CAPE filing. This is a fixed-fee analysis plus a success-based share of recovered duties.
Deadlines and Timing
IEEPA refund claims are time-sensitive. The specific deadlines depend on when your entries were filed and when they liquidated, but the general principle is this: don't wait. Every month you delay is a month closer to the deadline — and once it passes, the money is gone.
If you haven't screened your entries yet, the time to start is now.
Next Steps
If you're a small or mid-sized importer and you've been paying tariffs on goods from countries affected by IEEPA executive orders, you should screen your entries for refund eligibility. Start with the self-service screener if you want a quick look, or contact me directly if you want a full portfolio review.