Frequently Asked Questions
Answers about the IEEPA refund opportunity, how to protect your rights, and how we work.
Common Questions
THE REFUND OPPORTUNITY
Q1: Are IEEPA tariffs eligible for a refund?
Yes. On February 20, 2026, the Supreme Court ruled in Learning Resources v. Trump that IEEPA does not authorize the president to impose tariffs. On March 4, the Court of International Trade issued a Universal Refund Order directing CBP to process refunds for all importers of record. Two days later, on March 6, the CIT amended that order — staying its immediate enforcement while CBP builds CAPE, a new system to handle refunds at scale. The March 6 order did not nullify the refund obligation; it suspended the enforcement mechanics while CBP develops the infrastructure to comply. The legal foundation is established. The administrative mechanics are still being worked out.
Q2: Which tariffs are covered?
The ruling covers all tariffs imposed under IEEPA, paid between February 4, 2025 (when the “fentanyl tariffs” on Canada, Mexico, and China took effect) through February 24, 2026 (when IEEPA duties were stopped). This includes the April 2025 reciprocal tariffs on most trading partners, as well as IEEPA tariffs on Venezuela, Brazil, and Russia. Section 301 China tariffs, Section 232 steel and aluminum duties, and AD/CVD duties are not covered — they remain in place under separate legal authority.
Q3: How much money could I recover?
Per CBP’s own court filings, over 333,000 importers paid approximately $166 billion in IEEPA duties across 53 million individual entries. With accrued interest, total refunds could exceed $175 billion. Your specific recovery depends on your import volume, countries of origin, the HTS codes involved, and the IEEPA rates applied to each entry. We review your import history and provide you with a clear picture of what you may be owed before you commit to anything.
Q4: Does the refund include interest?
Yes. CBP has acknowledged the obligation to pay interest alongside IEEPA refunds. Under 19 U.S.C. § 1505(b), interest accrues on customs overpayments at the rate set quarterly under IRC § 6621, compounding daily under § 6622. Interest runs from the date of overpayment, so larger and older entries earn more. We factor interest into all recovery estimates.
Common Questions
THE REFUND OPPORTUNITY
Q5: What is the CAPE system?
CAPE stands for Consolidated Administration and Processing of Entries. On March 6, 2026, CBP proposed this new ACE portal functionality to the Court of International Trade as its plan for processing IEEPA refunds at scale — replacing manual entry-by-entry liquidation with an automated, electronic system capable of handling 53 million entries across 333,000+ importers. The CIT accepted CBP’s proposal and stayed its immediate refund order to allow the system to be built. The timeline for launch remains uncertain. Our team monitors CAPE developments weekly and keeps our clients informed of every update.
Q6: Do I need to file anything to protect my refund?
This is still evolving — and that uncertainty is exactly why working with an experienced team matters. The March 4 Refund Order was explicit that refunds apply to all importers of record, not only those who filed lawsuits or protests. However, the government has argued in court that only importers who affirmatively file claims will receive refunds. For liquidated entries approaching the 180-day protest window, filing a protective protest is the prudent step. It keeps your entry eligible regardless of how the legal dispute or CAPE unfold. We track entry status and protest windows as part of every consultation.
Q7: What is the 180-day protest window and why does it matter?
Under 19 U.S.C. § 1514(a), importers have 180 days from the date an entry is liquidated to file a formal protest with CBP. After that window closes, the entry becomes final. The CIT’s Universal Refund Order explicitly covers unliquidated entries and liquidated-but-not-final entries. Recovery on finally-liquidated entries may require CIT litigation. Most IEEPA entries are still either unliquidated or within the protest window — but entries from early-to-mid 2025 are actively liquidating. If you have not reviewed your entry status recently, some of your entries may be closer to that threshold than you think.
Q8: How long will it take to receive a refund?
The honest answer is: unknown. CAPE is still being built, and a system processing 53 million entries will face technical and validation delays well beyond its launch date. The government is also contesting the scope of the CIT’s order, which could introduce further delays. For importers who need working capital now, we offer an option to receive 20% of your anticipated refund upfront — putting cash in your hands without waiting for CBP to act.
Q9: My freight forwarder said they handled everything. Am I covered?
Possibly — but coverage varies significantly. Many freight forwarders and customs brokers have filed protests for active clients, but not necessarily for all entries, all time periods, or all importer-of-record numbers you may have used. We recommend verifying with your broker which specific entries were covered and cross-checking against your full import history. We can review your entry data to identify any gaps, even if your forwarder has handled part of the process.
Common Questions
WORKING WITH US
Q10: What does Tariff Refund Partners do?
We operate two core services. First, our Managed Filing Service — we review your import history, track your entry status and protest windows, monitor CAPE and litigation developments, and manage the refund process on your behalf for a flat fee. Second, our Claim Advance — for importers who need cash now, we offer 20% of your anticipated refund upfront while we handle the recovery process. Both services begin with a free discovery call so you understand your eligibility before deciding how to proceed.
Q11: Is Tariff Refund Partners a law firm?
No. Tariff Refund Partners, LLC is a consulting and financial services firm specializing in customs duty recovery and claim monetization. We are not a law firm and do not provide legal advice. CBP protest filings and the CAPE submission process are administrative — they do not require legal representation, and we manage them as part of our service. For entries requiring CIT litigation or formal legal counsel, we refer clients to licensed customs attorneys.
IMPORTANT
CAPE LEGAL UPDATE NOTE
Legal Update: CAPE System & Your Refund Rights
On March 6, 2026, CBP proposed the CAPE system — Consolidated Administration and Processing of Entries — to the Court of International Trade as its mechanism for processing IEEPA tariff refunds at scale. The CIT accepted the proposal and stayed its immediate Universal Refund Order while CBP builds the infrastructure. The refund obligation is not nullified — it is pending. Our team is actively monitoring all CBP guidance, CIT rulings, and CAPE developments on a weekly basis to ensure our clients’ claims remain compliant and protected. The 180-day protest window is running. Do not wait.