IEEPA tariff refund: who is eligible, how the process works, and how long it takes

What happened

On 2026-02-20 the Supreme Court decided Learning Resources, Inc. v. Trump (No. 24-1287, with Trump v. V.O.S. Selections, No. 25-250). The syllabus reads: “IEEPA does not authorize the President to impose tariffs.” The case covers the fentanyl tariffs (EO 14193, 14194, 14195) and the reciprocal tariffs (EO 14257). The opinion itself says “One issue will be refunds.”

CBP stopped collecting. In CSMS 67834313 it states that the duties under those orders “will no longer be in effect and will no longer be collected for goods entered … on or after 12:00 a.m. eastern time on February 24, 2026”. Section 232 and Section 301 duties are not affected. A 7501 that shows an IEEPA line on an entry dated on or after 2026-02-24 is an error to correct, not a refund.

The refund process: CAPE

CBP built the Consolidated Administration and Processing of Entries (CAPE) in the ACE Secure Data Portal. It went live on 2026-04-20 (CSMS 68340863). CBP’s wording: “CAPE Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation.” Later phases are to add “more complicated scenarios”.

• Who files: the importer of record or the broker that filed the entries. A list of entry numbers in a CSV file, up to 9,999 per declaration.
• How you are paid: by ACH only, to a U.S. bank account enrolled in the ACE Portal, to the importer of record or the CBP Form 4811 party.
• What CAPE takes today (CBP notice updated 2026-07-10): most entries that are unliquidated or up to 80 days past their liquidation date.
• What CAPE rejects: type 09 reconciliation entries; drawback entries; warehouse entries (types 21 and 22); entries covered by an open protest; entries not filed in ACE or without a liquidation status; AD/CVD entries with Commerce liquidation instructions pending; entries for which liquidation is final. CSMS 68340863 adds type 08 and 47 entries, an entry summary more than 80 days past the liquidation date, and entries on which a surety paid IEEPA duties. A Post Summary Correction may not be used to start an IEEPA refund.
• Deadline: none is stated in CBP’s CAPE messages or notice that we read. The 80-day limit after liquidation is the practical one.

Which headings are covered

The table lists the Chapter 99 headings we hold for China, Hong Kong and Macau, with the entry dates each duty applied and CBP’s status. Duty printed on a 7501 line under one of these headings, with an entry date inside the span, is an IEEPA duty.

Conditions as CBP states them

• CSMS 68340863 (2026-04-13): entry over 80 days past liquidation not accepted; open or suspended protest, drawback, AD/CVD pending liquidation, type 08/09/47 not accepted
• No CBP refund process; CIT relief only for named plaintiffs (Slip Op. 26-47, 26-53); appeal pending

Table generated 2026-10-21 from US IEEPA / Section 232 / Section 122 layers and refund status (hand-maintained). Entry dates are the dates the duty applied; "in force" means no end date is recorded.

Other origins (Canada, Mexico, Brazil, India, per-country reciprocal headings) are not in this table yet. A heading missing from it is “not checked”, never “not eligible”.

Section 122 is a separate 10% surcharge on entries from 2026-02-24 to 2026-07-23 (CSMS 67844987). The Court of International Trade held it unlawful for named plaintiffs only; for anyone else no CBP refund process exists.

What the 7501 cannot tell you

A 7501 does not show liquidation status, and CAPE eligibility depends on it. Purserhouse reads each Chapter 99 line, matches heading, origin and entry date to the table above, and adds up the duty printed on the lines inside a refund span. It never states a refund as certain, never calculates interest, and says “check the liquidation status in ACE” (reports ES-003 and ES-022). It is a reading of your document, not legal advice.

Try a few lines of your own entry.

In this section

Sources

• Supreme Court, Learning Resources v. Trump, No. 24-1287 (2026-02-20)
• CBP CSMS 67834313: IEEPA duties no longer collected (2026-02-22)
• CBP CSMS 68340863: CAPE and the CIT orders (2026-04-13)
• CBP CSMS 68315804: CAPE (2026-04-10)

Updated: 2026-10-21