How to claim your IEEPA tariff refund: a step-by-step guide for U.S. importers

Before you start: three things to confirm

Before you spend any time on the five-step path below, confirm three things. Each takes ten minutes and saves you from filing into a wall.

• You are the Importer of Record (IOR) on the entries. CAPE refunds flow only to the IOR named on the original CBP Form 7501 entry summary. If your foreign supplier shipped DDP and was the IOR, the refund is theirs, not yours — renegotiate commercially. If you are the IOR, your CBP-assigned IRS number (or CBP-issued importer number) is what CBP will match against.
• You are enrolled in ACH refunds. Per CBP's launch-week notice, fewer than 10% of affected importers had ACH refund enrollment active on April 20, 2026. Without it, your accepted refund queues in suspense indefinitely. File CBP Form 400 ("Application for ACH Refund") at cbp.gov/trade/automated/ach now — activation takes 5-15 business days.
• You have ACE Secure Portal access for your filer/importer account. CAPE is a module inside the existing ACE Portal — no new login. If your broker has historically held ACE access on your behalf, you either need them to upload on your filer code, or you need to provision your own ACE account at ace.cbp.dhs.gov with the Trade Account Owner role. Identity proofing through Login.gov takes 1-3 business days.

Step 1 — Pull your ACE ITRAC export

The ACE Importer Trade Activity (ITRAC) report is CBP's canonical view of every entry filed under your importer-of-record number. It is the single source of truth for refund work — more reliable than your broker's entry-summary file, more comprehensive than your accounts-payable duty ledger, and the report against which CBP's CAPE validator reconciles every claim line.

To pull it, log in to the ACE Secure Portal, navigate to Reports → Trade → ITRAC Reports, and request the standard ITRAC export with these settings:

• Date range: February 1, 2025 through February 20, 2026 — the window covering all nine struck IEEPA executive orders. If you also want to capture pre-IEEPA baselines for comparison, extend the start date back 90 days.
• Importer of Record: your IRS/EIN-derived CBP importer number. If you operate through multiple IOR numbers (e.g. parent + subsidiaries), pull each separately.
• Format: CSV (preferred over PDF — you cannot reconcile a PDF row-by-row).
• Columns: request the full column set, not the abbreviated default. You need at minimum: Entry Summary Number, Entry Date, Liquidation Date, Liquidation Status, HTS Number, Chapter 99 HTS, Country of Origin, Entered Value, Duty Amount, Estimated Duty Paid by Component, MPF, HMF, and Filer Code.

ITRAC reports are typically delivered to your ACE inbox within 24-48 hours of request. For very large importers (10,000+ entries in the period), the export may be split into multiple files — keep them in order and concatenate by Entry Summary Number when you reconcile.

Our companion piece, how to read your ACE ITRAC report for IEEPA refund eligibility, walks through every field you need to scan and the seven columns that actually drive the refund math.

Step 2 — Identify your Chapter 99 IEEPA lines

The HTSUS uses Chapter 99 as a parking lot for special-programme tariff modifiers — additional duties layered on top of a Chapter 1-97 commodity classification. Every Trump-era trade action lives there. The trick is knowing which 9903 codes are IEEPA (refundable) versus Section 301, Section 232 or AD/CVD (not refundable). We cover the full taxonomy in IEEPA vs Section 301 vs Section 232: which tariffs are refundable?; here is the IEEPA-specific subset to look for in your ITRAC.

Filter your ITRAC for any line where the Chapter 99 HTS field falls inside the green-shaded ranges above. Those are your IEEPA-refundable candidates. Total the "IEEPA Duty Paid" column across that filtered set — that is your gross potential refund. Most mid-market importers find this number lands somewhere between $80k and $4M; large industrial importers routinely surface $10M+.

Step 3 — Pick your refund pathway

There are four possible channels for an IEEPA refund, and the right one depends on the entry's liquidation status and timing. Choose wrong and you waste your statutory clock; choose right and the refund moves through CBP's fastest available queue.

Pathway A — CAPE Phase 1 (the default for most refundable entries)

Use when: the entry is unliquidated, OR was liquidated within 80 days before April 20, 2026 (i.e. roughly January 30, 2026 onwards).

Mechanism: CSV upload to the CAPE module of the ACE Secure Portal, per CSMS #68340863.

Timeline: 60-90 days from acceptance to ACH credit. Statutory interest under 19 USC § 1505(c) at the IRS overpayment rate (currently 6-7%) accrues from the original deposit date.

This is roughly 63% of the eligible pool — Penn-Wharton's modelling on the $166-179B refundable universe. CBP's CAPE FAQ is the authoritative source on Phase 1 scope. We cover the mechanics in detail in what is CAPE? CBP's IEEPA refund portal explained.

Pathway B — Post Summary Correction (PSC)

Use when: the entry is unliquidated, but you cannot or do not want to use CAPE — for example, because you are also correcting classification, valuation, or origin on the same entry, and want to bundle all corrections into one ABI submission.

Mechanism: standard PSC via your broker's ABI software, under 19 CFR § 141.61. Statutory deadline: within 300 days of entry, no later than 15 days before liquidation.

When this is the better path: if your IEEPA refund is bundled with a misclassification correction or a missed FTA preference, PSC handles all three corrections in one filing. CAPE is IEEPA-only.

Pathway C — Protest (CF-19)

Use when: the entry was finally liquidated more than 80 days but less than 180 days before today — i.e. it falls outside CAPE Phase 1 but inside the protest window under 19 USC § 1514.

Mechanism: file CBP Form 19 ("Protest") within 180 days of liquidation, per 19 CFR Part 174. Cite the Learning Resources, Inc. v. Trump ruling and EO 14389 as grounds; request refund of the IEEPA duty plus statutory interest.

Why this path matters: Phase 2 of CAPE (covering finally-liquidated entries) has no published live date as of April 2026. A protective CF-19 protest preserves your statutory rights regardless of when (or whether) Phase 2 launches. Many large importers are filing protective protests on every entry liquidated between August 2025 and January 2026 to keep options open.

Pathway D — Court of International Trade (CIT) action

Use when: CBP denies your CAPE submission, denies your protest, or fails to act within statutory windows — and the dollar amount justifies litigation.

Mechanism: file at the U.S. Court of International Trade in Manhattan within 180 days of CBP's protest denial, under 28 USC § 2631. Cases are typically consolidated where multiple importers raise identical issues.

Threshold: CIT litigation runs $200k-$1M in legal fees through summary judgement. Most importers reserve this for refunds >$5M or where a denied protest establishes precedent that affects multi-year forward exposure.

Step 4 — Build the filing packet

The packet has three components regardless of pathway: the structured submission file, the evidence pack, and the certifications. The detail varies by channel.

4a — The structured submission file

For CAPE Phase 1, this is a CSV file matching CBP's published schema in CSMS #68340863. One row per entry-line combination. Columns:

• Entry number — the 14-character CBP entry identifier (filer code + 7 digits + check digit)
• Line number — the line within the entry summary
• Original HTSUS — the 10-digit HTSUS commodity classification
• Chapter 99 secondary HTSUS — the 9903.xx.xx code under which IEEPA was assessed
• Entered value — must reconcile to the penny against ACE
• IEEPA duty paid — the dollar amount actually collected on the IEEPA Chapter 99 line, after EO 14289 stacking adjustment
• Claim amount — equal to IEEPA duty paid (over-claims trigger automatic rejection)
• Refund reason code — CBP-published code mapping to the specific rescinded EO

For PSC, the structured submission goes through your broker's ABI software as a standard Type 06 entry summary correction. For Protest, it is a CBP Form 19 with the entry list attached as Schedule A.

4b — The evidence pack

CBP does not require evidence to be attached to a CAPE CSV submission — the validator uses ACE's own data. But you should build the evidence pack regardless, because (a) Phase 2 and Protest filings will require it, and (b) if CBP queries any line, you need to respond within 30 days. The pack contains, for each claimed entry:

• The CBP Form 7501 entry summary as filed
• The commercial invoice and packing list
• Bill of lading or air waybill
• Country-of-origin declaration or certificate
• The original ACE entry-summary detail showing duty by component
• Proof of duty payment (PMS statement or ACH debit confirmation)

Most of this is already in your broker's filing archive. Pull it once at packet-build time rather than scrambling under a 30-day query response window later.

4c — The certifications

For PSC and Protest, CBP requires a compliance officer signature certifying the accuracy of the claim under penalty of 19 USC § 1592 (false claims). For CAPE, the ACE Portal upload itself constitutes the certification — but the IOR's authorised user must be the one uploading. If a customs broker is uploading on your behalf, ensure their Power of Attorney (POA) on file with CBP covers post-entry refund work; some older POAs do not.

Step 5 — Upload to the ACE Portal and track

For CAPE: log in to the ACE Secure Portal, navigate to Trade → CAPE Refund Submission, and upload your CSV. CBP rate-limits to 10,000 lines per upload per importer per day; if you have a larger portfolio, batch by entry date and submit across days. The portal returns a submission ID immediately. You can track status under Trade → My CAPE Submissions; statuses are: Received → Validating → Accepted / Rejected → Queued for Re-liquidation → Re-liquidated → Refund Issued.

For PSC: your broker submits via ABI; tracking happens through normal entry-summary status views. For Protest: file via the ACE Protest module or by paper CF-19 to the relevant Port Director; CBP has 2 years to act, but in practice most IEEPA-grounded protests are being acted on within 90 days given the volume.

The expected timeline

• Day 0: CSV uploaded to ACE Portal. Submission ID returned immediately.
• Day 1-2: Automated validation. Most rejections happen here — the most common is "Unable to calculate duty," caused by penny-precision mismatches between the CSV and ACE source data.
• Day 3-30: Accepted submissions queue for re-liquidation. CBP processes roughly FIFO across importers.
• Day 30-60: Re-liquidation. CBP recomputes duty without the struck IEEPA component.
• Day 60-90: ACH refund credited, plus statutory interest.

The interest math, with a real example

Statutory interest under 19 USC § 1505(c) is paid at the IRS overpayment rate, which has been 6-7% annualised since Q4 2024 and is reset quarterly. Interest accrues from the date the original duty was deposited (the entry-summary deposit date, not the entry date) to the date of refund.

Worked example. An importer paid $1.8M of IEEPA reciprocal tariffs on entries filed June through November 2025, with an average deposit date of August 15, 2025. CSV submitted April 25, 2026; refund credited July 20, 2026. Interest period: 11 months and 5 days = 0.93 years. At 6.5% blended: $1.8M × 6.5% × 0.93 = $108,810 in interest. Total refund: $1,908,810.

Watch out for: common rejection patterns

From CBP's published validation telemetry and the practitioner reporting in the first 30 days of CAPE Phase 1, six rejection patterns account for roughly 80% of returned submissions:

• "Unable to calculate duty" (penny-vs-dollar precision). ACE stores duty to penny precision; ITRAC roll-ups round to the dollar. CSVs built off rounded ITRAC figures fail reconciliation. Fix: pull duty from the ACE entry-summary detail, not the ITRAC roll-up.
• EO 14289 stacking over-claim. Treating IEEPA as collected when §232 stacking actually suppressed it. Fix: always net IEEPA against §232 collected duty for stacked Canada/Mexico steel/aluminium and auto entries.
• Wrong refund reason code. CBP publishes a finite list of reason codes mapping to the nine rescinded EOs. Mismatched codes (e.g. claiming a 9903.01.xx fentanyl line under a reciprocal-EO reason code) reject. Fix: build your code map once from CSMS #68340863 and apply it deterministically.
• Mixed Chapter 99 lines. Some entries carry both IEEPA and §301 Chapter 99 codes; only IEEPA is refundable. Including the §301 dollars in your claim is a §592 false-claim exposure, not just a rejection. Fix: filter Chapter 99 codes against the refundable list before totalling.
• NRI / foreign IOR claiming through a U.S. agent. ACH enrollment for non-resident importers is materially harder; many submissions sit pending. Fix: enrol via CBP Form 400 with a U.S. agent's banking details, or route refunds through your customs broker's bond.
• Phase 2 entries filed in Phase 1. Entries liquidated more than 80 days before April 20, 2026 reject. Fix: check the Liquidation Date column before claiming; preserve those entries via CF-19 protest instead.

Frequently asked questions