RGCI - Businesses Can Now Claim IEEPA Tariff Refunds Through the New Portal

The launch of the CAPE (Consolidated Administration and Processing of Entries) system by U.S. Customs and Border Protection marks a significant opportunity for importers to recover duties previously paid under IEEPA tariffs that were later ruled invalid by the U.S. Supreme Court. By enabling consolidated refund claims and streamlining the process through the ACE portal, this program reduces administrative burden and accelerates reimbursement. For importers, especially small businesses that directly paid these tariffs, this development is highly relevant because it provides a time-sensitive pathway to reclaim costs, improve cash flow, and correct past overpayments in a changing tariff environment.

Requesting refunds of IEEPA duties requires only the following summarized actions:

  • Importers of Record and authorized Customs brokers have an established ACE Secure Data Portal account (ACE Portal account)
  • Recipients use the ACE Portal account to provide CBP with bank account information
  • Importers of Record and authorized Customs brokers submit CAPE Declarations in the ACE Portal (see details in the article below)

Step-by-Step Guide: Import Tariff Refunds (IEEPA)

Step 1. Understand Eligibility

Importers should begin by determining whether the duties at issue fall within the limited scope of the current refund process. Confirming that threshold issue first can help avoid unnecessary filing effort and keep attention on claims that align with CBP’s current parameters. Before anything else, importers should confirm that their situation falls within the scope of the refund program. Eligibility turns on who paid the duty and under which authority it was imposed:

  • Refunds apply to tariffs imposed under IEEPA that were invalidated by the U.S. Supreme Court.
  • Only businesses that directly paid IEEPA import duties are eligible.
  • Businesses affected indirectly (e.g., higher supply chain costs without paying tariffs) are not eligible.

Step 2. Confirm Entry Eligibility

After establishing that the business itself may qualify, importers should review whether the specific entries they intend to include meet CBP’s current requirements. This step is important because the refund process is limited to certain entry statuses and filing windows, not all past imports. Even for eligible businesses, not every past import entry qualifies. CBP limits claims to entries that are still open or were only recently liquidated:

  • Eligible entries include:
    • Unliquidated entries.
    • Entries liquidated within the last 80 days (generally covering imports from approximately the past 314 days).
  • Verify entry status and dates in the ACE portal.

Step 3. Ensure System Readiness

Importers should confirm that the required account access and payment information are already in place before filing. Since the refund process is administered through CBP’s online systems, resolving those items early can help reduce avoidable delays once a claim is ready to be submitted. Because the entire refund process runs through CBP's online systems, importers should confirm their accounts and payment details are ready before filing:

  • The Importer of Record (IOR) and any customs broker must have an active ACE Portal account.
  • Confirm banking details are up to date in ACE.
  • A valid U.S. bank account is required for ACH refunds.

Step 4. Access the CAPE Portal

Once eligibility, entry status, and account readiness have been reviewed, importers need to make sure they are using the correct CBP platform for submission. This step is important because CAPE is the designated system for these claims and serves as the entry point for the refund process. CAPE is the new module within ACE that CBP built specifically for handling IEEPA refund claims:

  • Log into the ACE portal and navigate to the CAPE (Consolidated Administration and Processing of Entries) system.
  • CAPE launched April 20, 2026, as the official platform for IEEPA refund claims.

Step 5. Submit Consolidated Refund Claims

One of the most significant features of CAPE is the ability to consolidate eligible entries into a single submission. That change can reduce administrative burden, but importers still need to ensure the filing is complete and supported by the required entry information and documentation. The key efficiency gain of the new portal is consolidation. Importers no longer need to file one correction per entry:

  • File claims through CAPE instead of submitting individual entry corrections.
  • CAPE allows multiple eligible entries to be grouped into a single claim.
  • Provide all required entry details and supporting documentation.

Step 6. Refund Processing and Payment

After a claim is submitted, importers should understand how reimbursement will be handled and what timing to expect. That visibility can help businesses plan for the recovery of funds and related cash flow impact. Once a claim is approved, CBP handles interest and disbursement automatically, though importers should plan for a multi-month payment window:

  • Approved refunds will include applicable interest automatically.
  • Payments are issued electronically via ACH.
  • Expected payment timeline is 60–90 days after claim approval.

Step 7. Track and Manage Claims

Submitting the claim does not end the process. Importers should continue monitoring claim activity and be prepared to respond if CBP requests clarification or additional support, since delays at that stage may affect reimbursement timing. Filing is not the end of the process. CBP may follow up for clarification, and delays in responding can hold up payment:

  • Monitor claim status within the ACE portal.
  • Respond promptly to any CBP requests for additional information.

Step 8. Understand Phase 1 Limitations

Importers should also keep in mind that the current release reflects only an initial phase of the refund program. A business that is not covered now may still need to preserve records and monitor future updates if eligibility expands later. The current portal reflects only the first phase of CBP's refund program, and businesses not covered today may still benefit later:

  • Not all businesses or entries are eligible in this initial rollout.
  • Future phases are expected to expand eligibility.
  • Maintain records of all IEEPA-related entries for potential future claims.

Step 9. Stay Informed on Current Tariffs

The availability of IEEPA refunds does not eliminate broader tariff exposure or ongoing legal uncertainty. Importers should continue monitoring related tariff actions so they can distinguish between duties that may be recoverable and those that remain in effect. The IEEPA refunds do not mean tariff exposure has gone away. Other duties remain in force, and the legal landscape is still shifting:

  • A separate 10% global tariff under Section 122 (effective Feb. 24, 2026) is currently in place for 150 days.
  • These tariffs are not eligible for IEEPA refunds.
  • Ongoing legal challenges may impact future tariff policies and refund opportunities.

The Scale of the Refunds

Based on April 2026 reports, approximately $160 billion to $166 billion in International Emergency Economic Powers Act (IEEPA) tariff refunds are expected to be issued to U.S. businesses following the Supreme Court ruling, with some projections reaching as high as $170 billion. CBP estimates that between 56,000 and 330,000 importers and brokers may be eligible, having paid these tariffs on over 53 million shipments. For full program details, eligibility criteria, and filing guidance, visit CBP's official page.

Import, Export, and Contract Compliance Considerations

For government contractors, IEEPA tariff refunds should be evaluated in connection with broader import, export, contract, and accounting requirements. Redstone GCI helps contractors review contract clauses, subcontract flowdowns, purchasing documentation, and accounting records to determine how refund claims and related import activity should be handled and documented. This can include support with import and export compliance considerations, process reviews across procurement and accounting, training for internal teams, and operational support to help maintain records, address reporting questions, and prepare for audit or compliance.

Written by Carolyn Turner

Carolyn Turner Carolyn Turner is an Export/Import Compliance Consultant at Redstone Government Consulting, Inc., specializing in international trade regulations, including International Traffic in Arms Regulations (ITAR) and Export Administration Regulations(EAR) on the export side. She provides guidance on import compliance matters such as customs clearance, classification, free trade agreements, country of origin requirements, duty drawback, and supply chain analysis. Carolyn advises contractors on regulatory compliance and develops policies and procedures to support effective international trade operations. Since 2002, Carolyn has held roles including International Research Analyst, International Trade Specialist, and Assistant Director or Research and Training at the Alabama International Trade Center, where she conducted market analyses, and provided training and consulting to small and medium-sized businesses across all industry sectors. She also has experience in freight forwarding working as the NVO coordinator for both imports and exports. And she has also served as an Adjunct Professor at the University of Alabama, developing and teaching online International Business courses.Carolyn is a Licensed U.S. Customs Broker and a NASBITE Certified Global Business Professional. She is proficient in Spanish. Her skills include Incoterms, import and export documentation, ITAR/EAR, free trade agreements, compliance program development, and international finance.She holds a B.S. in Commerce and Business Administration and a Master’s in Management with a Global Business Concentration from the University of Alabama. Carolyn serves on the boards of the Japan America Society of Alabama, Destination Hoover International, and BIO Alabama, and is a member of the Export Alabama Alliance.

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

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Topics: Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting