Who Actually Gets Your Tariff Refund?

Get a heads-up on China import duty changes

before they hit your customs bill

The refund rules above are moving monthly - phases open, the appeal advances, payout timelines shift - and the forward-looking tariffs change too. We send a short email every month: what changed, dates to watch, and a simple cost example. Important changes that can't wait get a separate email. No spam.

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If your business imported from China (or anywhere else) during 2025, part of what you paid at the border was collected under the International Emergency Economic Powers Act - the "IEEPA" tariffs. Courts struck those tariffs down, and they stopped applying to goods entered on or after 24 February 2026. On 20 April 2026, CBP launched CAPE (Consolidated Administration and Processing of Entries) inside the ACE portal to pay the money back, consolidated by importer, with interest calculated under 19 U.S.C. § 1505 and netted into the payment.

That is the good news. The bad news is that a lot of that money is about to be paid to the wrong-feeling party: the legal importer of record, which for many small businesses is a courier's brokerage entity or a forwarder - not the business that actually absorbed the cost. Start with the five-minute check below before the checks go out.

The five-minute check: pull a 7501 and read Box 26

Every formal customs entry has an entry summary - CBP Form 7501. Box 26 is "Importer of Record Name and Address." Whoever is named there (or a party they formally designate on CBP Form 4811) is who CBP pays. Ask your customs broker, forwarder, or courier for the 7501s on your 2025 entries and read that box.

• Your business is in Box 26: the refund right is yours. Follow the claim steps in the next section - it is genuinely doable in-house for clean entries.
• A courier or its broker is in Box 26 (common for FedEx/UPS/DHL-cleared parcels - see how a courier customs bill is built - and many DDP shipments): CBP pays them, and you depend on their pass-through process. In July, trade press reported that FedEx planned to start mailing refund checks in August 2026, and that UPS planned to apply refunds first to customers' open invoices before disbursing the rest. That timetable has passed, and this 3 September verification found no primary-source notice confirming completion. Those are carrier processes, not CBP rules. Contact your carrier's brokerage department, confirm whether you are on its refund list, and confirm the entity and address it will pay.
• Your supplier or a forwarder is in Box 26 (typical when you bought DDP - "delivered duty paid"): the refund right sits with them. Whether any of it reaches you is a contract and negotiation question, not a CBP process - CBP has published no DDP-specific guidance and does not referee who-really-paid disputes.

One more wrinkle worth knowing: refunds can be reduced or diverted before they reach anyone - CBP nets them against underpayments on the same entry (19 C.F.R. § 159.1) and against unpaid debts to the U.S. (19 C.F.R. § 24.72). If the number that arrives is smaller than the number you computed, that is often why.

CAPE refunds the IEEPA layer, not Section 301

This is the single most-confused point, so here is CBP's own wording from its IEEPA Duty Refunds page:

"The General Duty rate, plus other duties, such as Section 232, 301, and/or 201, were and are still applicable. Under CAPE processing, the net amount after the proper calculations is what constitutes the IEEPA Refund or duties owed."

In plain terms: only the tariff lines under HTS 9903.01.xx and 9903.02.xx (the IEEPA layers) are refundable through CAPE. Your base duty stays. Section 301 stays. Section 232 stays. On a typical China-origin entry that was stacked with several layers, you get the IEEPA portion back and keep paying the rest. CBP's own worked example: if the general duty was 5% and IEEPA brought the total to 15%, the refund is the 10% IEEPA portion - the 5% base duty "is still applicable and is not part of the IEEPA refund."

Anyone who tells you Section 301 money is coming back through CAPE is wrong, and pricing your next order on that assumption is an expensive mistake. For what you still owe going forward, see today's China tariff rates.

How do I claim my IEEPA tariff refund from CBP?

1. Find what you paid. Run ACE report ES-003 (Entry Summary Line Tariff Details) and filter the HTS column for 9903.01.xx and 9903.02.xx - those lines are your IEEPA duties. If you do not run ACE reports yourself, your broker can pull this in minutes.
2. Get your ACE portal and banking set up - no ACE, no refund. CBP is blunt about this: refunds are paid by ACH only, to bank details enrolled in the ACE portal. From CBP's FAQ: "To get a refund, bank account information must be provided using an ACE Portal account." If CBP's record of your business is stale, or you imported as an individual under your SSN, the underlying importer record is CBP Form 5106 - a broker can file or update it for you. CBP's 18 August update says importers should also run ACE report REV-613 to find refunds rejected because ACH enrollment was missing, enroll, and notify CBP refund support.
3. File the CAPE Declaration. It is a CSV file of entry numbers - one column - uploaded in the CAPE tab of the ACE portal (template behind the Upload button), up to 9,999 entries per declaration, multiple declarations allowed. Only the importer of record or the broker who filed the entries may submit it.
4. Wait 60-90 days, and expect installments. CBP's guidance: valid refunds are "generally issued within 60 - 90 days following acceptance of the CAPE Declaration." Importers commonly report the money arriving in tranches. Track status with ACE report ES-022 (CAPE Entry Summary Report).
5. Pay no one a "release fee." CBP: "CBP does not charge any fees for processing tariff refunds. If you are asked to pay a fee ... it is a scam." Report scam attempts to traderelations@cbp.dhs.gov. A broker charging a reasonable hourly or flat fee to handle the filing is legitimate; a stranger demanding a cut to "release" your refund is not.

Official references for every step: CBP's IEEPA Duty Refunds hub, the ACH-setup bulletin CSMS #68179006, the timeline bulletin CSMS #68340863, the refund-monitoring reports bulletin CSMS #68536553, and the ACH-rejection bulletin CSMS #69570464.

Can a Section 301 exclusion lead to a separate refund?

Yes, where the entry qualifies. CBP CSMS #69990649 describes corrections or protests for goods covered by four amended exclusions, including eligible entries from 1 July through 22 September 2026. Filing periods still apply. This is a separate Section 301 process, not a CAPE claim. Ask your broker to check the full exclusion description.

Who can use CAPE Phase 3, and what changed for the refund class?

Targeted check, 15 October 2026: the October 8 Freestyle World opinion, page 22 confirms CBP deployed Phase 3 on 6 October. It permits plaintiffs with existing court orders covering their finally liquidated entries to file CAPE declarations.

Separately, the order on pages 32-33 certifies a class of importers of record who paid duties under the challenged IEEPA tariff orders between 1 February 2025 and 19 February 2026, excluding entities that separately sued to recover those payments. Class certification did not itself order class-wide refunds or reliquidation, or open Phase 3 to every class member.

The parties must propose a case schedule by 22 October. That is a court scheduling date, not an importer claim deadline. Check subsequent court orders and CBP's current filing instructions with your broker or counsel before acting.

Deadlines, phases, and the liquidation clock

This is the part of the refund story that is genuinely time-sensitive, and the part most likely to have changed by the time you read it - re-check the sources.

• Phase 1 (open since 20 April 2026): in CBP's words, "limited to certain unliquidated entries and certain entries within 80 days of liquidation."
• Phase 2 (open since 29 June 2026): per CSMS #69035485, CAPE now also accepts entries flagged for reconciliation (entry types 01, 02, and 06) where the reconciliation entry (type 09) has not yet been filed - still limited to unliquidated entries and entries within 80 days of liquidation.
• Warehouse treatment changed on 7 July 2026: warehouse entry types 21 and 22 are rejected from CAPE Declarations. Warehouse withdrawal types 31, 32, 34, and 38 remain accepted because that is where the IEEPA duty was paid. See CSMS #69127837.
• Finally liquidated entries: see the Phase 3 and class update above. Ask trade counsel to confirm your entries' eligibility and any steps needed to preserve your rights.
• Know your liquidation dates. A protest can only be filed within 180 days after liquidation (19 U.S.C. § 1514). A protest deadline and eligibility for court-ordered Phase 3 relief are different questions. Ask your broker or counsel which steps apply to your entries. Check where your entries stand with ACE report ES-701 (Courtesy Notice of Liquidation), and remember the legally operative notice is the official posting on CBP's bulletin, not the courtesy report.

A phase opening or class certification is not a payment promise or a deadline extension. Recheck CBP instructions and any order covering your entries before acting.

Not the importer of record? Read this before writing it off

DDP buyers: if your supplier quoted "delivered duty paid", their side arranged the entry and the importer of record is usually their forwarder's or courier's entity. The tariff cost was baked into your DDP price, but the refund right belongs to the party in Box 26. There is no CBP mechanism for you to claim it directly - your leverage is commercial: ask who the importer of record was, ask what happens to the refund, and factor the answer into whether that supplier relationship still prices fairly.

Downstream retailers: if you bought tariff-inflated goods from a US importer or distributor, you paid the tariff economically - once in your cost of goods, and again if your supplier does not pass the refund through. Honestly: CBP has no process for you. The refund follows the customs entry, full stop. What you can do is ask your supplier directly whether they are filing CAPE claims and whether any of it reaches your pricing - suppliers who want to keep your business have been known to share.

Individuals and one-off importers: the process technically works for you too (your importer record is CBP Form 5106, and a broker can set it up), but for a single small entry, weigh the setup effort against the refund honestly.

Refunds look backward. Your next order looks forward.

Everything on this page is about money already paid under a tariff that no longer exists. The tariffs that still affect new entries - base duty, existing Section 301 list tariffs, the new Section 301 forced-labor duty where applicable, Section 232, MPF, and HMF - are what decide whether your next order makes money. The temporary 10% Section 122 surcharge expired on 24 July 2026. That forward math is what this site's calculator does: landed cost per unit, breakeven, and a GO / TIGHT / NO-GO verdict before you wire a deposit.

Run my next order's landed cost →

Planning Information Only

This page is general information, not legal, customs, tax, or financial advice. The IEEPA refund process sits on top of active litigation - the government's Federal Circuit appeal could change who gets refunded and when, and CBP's phases, timelines, and procedures have changed repeatedly. Whether you can recover anything depends on your entries, your liquidation dates, and who your importer of record was. Verify the current state on CBP.gov, and for liquidated entries, protest deadlines, or importer-of-record disputes, talk to a licensed customs broker or trade attorney before relying on anything here.