IEEPA Tariff Refunds: What Importers Need to Know

Recent legal and policy developments have created opportunities for importers to recover certain duties paid under IEEPA tariffs. To support that process, U.S. Customs and Border Protection (CBP) is implementing Consolidated Administration and Processing of Entries (CAPE), a phased refund process within the ACE Secure Data Portal.

While the refund process itself is relatively straightforward, preparing a successful claim often is not. Organizations may need to review thousands of customs entries to determine which qualify, calculate potential refund amounts, and prepare CAPE-ready submissions.

That's where technology can make a significant difference.

How the IEEPA Refund Process Works

Eligible Importers of Record (IORs) submit refund claims through CBP's CAPE Portal using data from their ACE account. Depending on the phase of CAPE implementation, different categories of entries become eligible for review and refund.

The current rollout includes three phases:

• Phase 1 (launched April 20, 2026): Unliquidated entries and entries liquidated within 80 days of filing.
• Phase 2 (launched June 29, 2026): Reconciliation-flagged entries (types 01, 02, 06) where the reconciliation entry (type 09) has not yet been filed, still limited to unliquidated or 80-day liquidated entries.
• Phase 3 (rolling out in 2026, currently limited to importers with active CIT litigation): Finally liquidated entries (liquidated >80 days), currently limited to importers with active CIT litigation.

As eligibility expands, importers should periodically review historical entries to determine whether additional refund opportunities have become available.

Finding Eligible Entries Is the Real Challenge

For many organizations, the biggest challenge isn't submitting a CAPE claim—it's determining which entries belong in it.

Large importers often manage thousands of customs entries spanning multiple suppliers, brokers, ports, and tariff programs. Identifying eligible entries requires reviewing factors such as:

• Chapter 99 declarations
• Liquidation status
• Reconciliation status
• Entry type
• Applicable IEEPA duties

Trying to review this information manually can be time-consuming and increases the risk of overlooking eligible refunds.

Generate an IEEPA Refund Report in Minutes

BITE's ACE Analyzer was built to simplify this review process.

Users simply upload an ACE ES-003 report, and BITE automatically analyzes the underlying customs data to generate an IEEPA Refund Report highlighting potentially eligible entries and estimated refund opportunities.

The workflow allows trade compliance teams to:

• Upload ACE ES-003 reports
• Automatically generate an IEEPA Refund Report
• Identify potentially eligible refund entries
• Estimate refund values in bulk
• Review liquidation and reconciliation status
• Export refund calculations in CAPE-ready format

Instead of spending days reviewing spreadsheets and customs data manually, compliance professionals can focus on validating results and preparing stronger refund submissions.

Beyond Refund Calculations

Recovering duties is only one part of effective post-entry compliance.

The same customs data used to identify IEEPA refunds can also help organizations uncover broader compliance issues, including:

• Incorrect Chapter 99 declarations
• Tariff calculation errors
• Potential duty overpayments
• Customs filing inconsistencies
• Post-entry audit priorities

Rather than treating IEEPA refunds as a one-time recovery exercise, many organizations use the process as an opportunity to strengthen their overall post-entry compliance program. Reviewing customs data systematically can help identify recurring filing issues, improve data quality, and reduce future compliance risk.

Who Can File an IEEPA Refund Claim?

Only the Importer of Record (IOR), or another party authorized under CBP procedures, may submit refund claims through the CAPE Portal.

Although the IOR is responsible for filing, the financial impact of tariffs often extends well beyond the importer. Finance, procurement, customs brokers, and supply chain teams may all have an interest in understanding potential refund opportunities and how recovered duties affect landed costs and pricing decisions.

See the IEEPA Refund Workflow in Action

BITE's ACE Analyzer combines ES-003 analysis, the IEEPA Refund Report, refund calculations, and CAPE-ready exports into a single workflow designed for high-volume post-entry compliance.

Whether you're evaluating newly eligible reconciliation entries under CAPE Phase 2 or preparing refund submissions across thousands of customs entries, BITE helps transform raw ACE data into actionable refund opportunities in minutes.