The CBP’s CAPE refund portal opened April 20, 2026. Here’s what your business needs to know — and do — right now.
If your business imported goods from China or other countries in 2025, there’s a good chance you’re owed money back. Following a recent Supreme Court ruling on the limits of executive trade authority, U.S. Customs and Border Protection is now processing refunds on certain import duties collected under the International Emergency Economic Powers Act (IEEPA) — but only for businesses that proactively file a claim. Refunds are not automatic.
The window to file is open right now, but it is governed by strict deadlines tied to your specific import records. Miss the window, and your options narrow significantly. TGG’s team is already helping clients assess their eligibility, calculate projected refund amounts, and get their filings in order before deadlines pass.
The first step is a free conversation with us here at TGG.
What Tariffs Are Being Refunded?
Not every tariff qualifies. It’s important to understand that there are longstanding, legitimate tariffs that were in place before 2025 and remain in place today — those are not part of this refund process. The refunds apply specifically to the incremental IEEPA emergency duties added on top of those baseline tariffs. Think of it as only a specific slice of what you paid, not the full tariff line item on your invoices.
This distinction matters enormously when estimating what you’re owed. If your supplier passed along a price increase and described it as “tariffs,” the refundable portion may be smaller than you expect. The CBP makes the final determination on all refund amounts, so any internal projections should be treated as estimates. That said, for businesses with significant import volume, the numbers can still be very large.
Who Can File a Claim?
Only the Importer of Record (IOR) — or an authorized customs broker who filed entries on their behalf — can submit a refund claim directly through CBP’s CAPE portal. If your business purchases through a U.S.-based distributor or third-party supplier rather than importing directly, you are not the importer of record and cannot file yourself.
That doesn’t mean you’re without recourse. You have every right to contact your supplier, ask whether they are filing for a refund, and request that the corresponding amount be passed back to you — since you absorbed the cost of the price increases when they occurred. Be aware, however, that there is currently no statutory requirement for importers to pass refunds downstream to their customers. Getting ahead of that conversation now, with documentation of the price increases you paid, is essential.
Not sure which category your business falls into? Contact TGG for a free assessment — we’ll tell you exactly where you stand.
⏲️ Understanding the Timeline: Liquidation Dates Are Everything
This is where most businesses get tripped up, and it’s worth understanding clearly.
Eligibility for Phase 1 refunds is based on the liquidation date of your import entry — not the date your goods arrived in the U.S. The liquidation date is when CBP officially finalizes the duty amounts on a given shipment, confirming that the HS codes, tariff amounts, and duties owed are all correct. That date can come weeks or even months after the goods cleared customs.
From the liquidation date, you have 90 days to file a refund claim. The portal itself displays an 80-day window, because CBP reserves approximately 10 days for document processing — but the underlying period is 90 days, and that’s what you should plan against. To find your liquidation dates, pull your CBP Form 7501 records.
If your liquidation date falls outside the 90-day window but within 180 days, you may still be eligible through a formal protest filing — a process that preserves your refund rights while CBP reviews the claim. Beyond 180 days, litigation becomes the only remaining path, and you’ll want legal counsel involved.
For businesses that have been importing regularly throughout 2025, the reality is you likely have a mix: some entries that qualify for Phase 1 and others that require a protest filing. Sorting out which entries fall into which bucket — quickly — is exactly the kind of work TGG can do for you.
Contact us today and we’ll map your entries to the right process at no cost.
FAQs: IEEPA Tariff Refunds
What is the IEEPA tariff refund program?
Following a Supreme Court ruling on the limits of executive trade authority, CBP is now processing refunds on certain import duties collected under IEEPA in 2025. The CAPE refund portal opened April 20, 2026, and businesses must actively file a claim to receive a refund — it is not automatic.
Which tariffs are eligible?
Only the incremental IEEPA emergency duties are eligible for refund. Pre-existing tariffs that were in place before 2025 — such as Section 301 duties on Chinese goods — are not part of this program and remain in effect.
How do I know if my business qualifies?
If your business is the Importer of Record on shipments that paid IEEPA duties in 2025, you likely qualify for at least a partial refund. Eligibility for Phase 1 depends on your entry’s liquidation date falling within the past 90 days. Entries with liquidation dates between 90 and 180 days ago may qualify through a protest filing. TGG can review your import records and determine your eligibility at no cost.
What is a liquidation date and where do I find it?
The liquidation date is when CBP officially finalizes the duty amounts on a given import entry — often weeks or months after the goods entered the country. You can find your liquidation dates in your CBP Form 7501 records or through the ACE Portal.
What if I’m not the importer of record?
If you purchase goods through a U.S. distributor or third-party supplier, you cannot file directly. However, you can and should contact your supplier to ask whether they are filing and to request that any refund be passed back to you. There is no legal requirement that they do so, which makes early, documented communication critical.
What if my 90-day window has already passed?
Entries with liquidation dates more than 90 days ago may still qualify through a formal protest, provided you act within 180 days of the liquidation date. Beyond that, legal action is the remaining option. TGG has referral relationships with litigation counsel for exactly this situation.
How long does it take to receive a refund once filed?
CBP estimates refunds will be issued within 60 to 90 days of a CAPE Declaration being accepted. Entries that require additional review may take longer.
How can TGG help?
TGG’s team is actively helping clients identify eligible entries, calculate projected refund amounts, prepare filing documentation, and navigate protest filings where needed. We offer a free initial assessment to determine your eligibility and map your next steps. Contact us today to get started.
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Janine Smith is a Consulting CFO with TGG. She has a wealth of experience in accounting process development and management, supervising both TGG staff and client’s internal staff (banking, AR, AP, inventory management, payroll), and working with many different types of accounting software. She has worked with clients to develop KPIs that fit their current needs and coached them to support the goals of the business. One of her favorite tasks is budget development and using that as a tool to help organizations meet their goals.