Tariff Refunds: How Companies Get Their Money Back

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The Supreme Court ruled on February 20, 2026, that the International Emergency Economic Powers Act, or IEEPA, does not authorize the president to impose tariffs. The ruling did not put refunds in companies’ bank accounts. Importers claim them, with interest, through U.S. Customs and Border Protection, or CBP, which removes the tariffs from their import records and processes the payments.

Refunds go only to importers or parties they designate, not to shoppers who paid higher prices.

The ruling ended IEEPA tariffs, not every duty

The decision did not ban tariffs in general. It reached only those imposed under IEEPA, and that limit determines which payments can be recovered.

CBP stopped collecting the covered IEEPA duties on goods entered for consumption, or withdrawn from a warehouse for consumption, on or after midnight Eastern time on February 24, 2026. The order ending those duties left other tariffs unaffected, including duties under Section 232 of the Trade Expansion Act of 1962 and Section 301 of the Trade Act of 1974. Section 232 has been used for steel and aluminum tariffs to protect national security. Section 301 addresses foreign government practices that are unreasonable, unjustifiable or discriminatory and burden or restrict U.S. commerce. An importer can therefore be seeking repayment of an old IEEPA charge while still owing other duties on new imports.

Congress has constitutional powers to regulate foreign commerce, impose tariffs and raise revenue, and it has delegated some tariff authority to presidents under specified conditions. Customs duties are both a tool of trade policy and a source of government revenue. The Supreme Court’s decision supplies the legal reason for removing IEEPA duties from these entries.

The importer’s payment controls who gets the refund

Importers pay tariffs: the importer of record generally deposits estimated duties with Customs, with exceptions in the law for particular payment and entry arrangements. That importer may be the owner or purchaser of the goods, or a licensed customs broker designated by the owner, purchaser or consignee. A tariff refund goes back to that importer, which may not be the company whose name a shopper sees on a receipt.

For IEEPA refunds, CBP pays the importer of record or the designated notify party on Customs Form 4811, using U.S. bank information recorded in its electronic system. A retail customer who paid a higher shelf price does not acquire a direct CBP refund claim merely because that price reflected a tariff. Whether a business shares its recovery with customers is a separate question from who receives the government’s customs payment.

CBP says most small businesses lack an account in its Automated Commercial Environment, or ACE, and use licensed customs brokers, whom they can continue using for IEEPA refunds. CBP is handling refunds in phases. For the first, which is limited to entries whose duties Customs has not finished calculating or finished calculating recently, CBP says importers do not need to file a Court of International Trade lawsuit to receive a refund due. The Court of International Trade is a federal court with nationwide jurisdiction over civil actions arising from U.S. customs and international trade laws. For those entries, a small business can recover duties without having been one of the companies that sued over the tariffs; what matters is whether each entry is eligible, not the size of the company. A small importer’s first step is to talk with the broker who filed its entries, rather than to assume every refund begins in court.

Check the entry status before choosing a route

The route depends on the status of each import record, known as an entry: eligible entries whose duties Customs is still calculating, or finished calculating in the past 80 days, can use CBP’s ordinary process, while older ones may need a court order.

Liquidation is Customs’ final calculation or determination of the duties on an entry. It is a step in settling the government’s bill, rather than a description of the company going out of business. The liquidation date matters because several deadlines run from it.

CBP processes IEEPA refunds through a system called Consolidated Administration and Processing of Entries, or CAPE. The initial CAPE refund phase covers certain unliquidated entries and certain entries recently liquidated. Entries liquidated within the preceding 80 days can be included, which leaves CBP time to recalculate them, a step called reliquidation, by the 90th day, its legal deadline for doing so voluntarily. An importer that waits until day 90 can therefore miss the 80-day filing window.

Reconciliation lets importers flag estimated information in an entry summary and later submit corrected information in a separate entry. CAPE’s second phase covers entries flagged for reconciliation when no reconciliation entry has been filed. Effective June 29, 2026, CAPE accepts specified entries of that kind, provided they are unliquidated or within 80 days of liquidation. An importer with a flagged entry should check the expanded instructions rather than assume the entry is excluded because it was not covered at launch.

An extension gives Customs more time to liquidate an entry when needed information is unavailable or an importer shows good cause for an extension. A suspension pauses liquidation as required by a statute or court order. Extended, suspended or under-review entries may be submitted where eligible, but they keep that status until the outstanding issue is resolved and refunds occur at liquidation.

As of a September 2, 2026, update, CBP was evaluating whether later versions of CAPE could handle more types of entries, including entries with open protests, certain reconciliation entries and entries tied to drawback claims. Drawback is a refund of certain import duties, taxes and fees when merchandise is exported or destroyed. If an entry falls into one of those categories, check CBP’s current instructions before concluding from a failed upload that no refund is possible. One business can have entries following more than one route, so a single company-wide eligibility answer can be misleading.

CBP prohibits initiating an IEEPA refund request through a post-summary correction, the procedure known as a PSC. A PSC normally lets a filer electronically correct entry-summary information before liquidation. That familiar customs correction is the wrong procedure for this repayment.

File through ACE and make the payment account usable

A CAPE declaration, the list of entries for which an importer requests refunds, is filed through the web-based ACE Portal. Only the importer of record or the licensed customs broker that filed the underlying entries may submit the CAPE declaration. Confirm which of those eligible filers will submit each group of entries before assembling a declaration.

The declaration uses a comma-separated values, or CSV, file containing entry numbers only, with up to 9,999 entries per declaration and multiple declarations permitted.

ACE report ES-003 identifies entry-summary lines with IEEPA duties, while ES-022 links accepted declarations to entries and refund numbers and separates principal from interest. Use the first report to assemble the relevant payments and the second to follow their progress.

Companies without ACE access must first ensure that their importer record on CBP Form 5106 has a current company email address, rather than the broker’s email. They then use CBP’s account application to obtain access with the Importer sub-account view. An existing ACE account lacking that view needs the Importer sub-account added.

The bank-payment information uses the Automated Clearing House, or ACH, system. An account owner or authorized user can use the Importer sub-account’s ACH Refund Authorization tab to view, add or update U.S. bank information. If current ACH information is missing from ACE, CBP holds the refund until that information is available. Set up the bank information early, even when a broker handles the filing.

CBP reported that, as of October 2, 2026, 20,362 refunds totaling approximately $1.1 billion had not been sent to Treasury because the importer or designated notify party had not provided ACH information.

CAPE creates no new recordkeeping requirements, and existing applicable requirements continue. Retain the entry records and the declaration’s results together so the claimed payments can be reconciled with the eventual refund.

Calculate the refund before expecting a bank deposit

Once a declaration is accepted, CAPE removes the IEEPA provision, listed in Chapter 99 of the Harmonized Tariff Schedule, and the corresponding duties from the entry. The refund starts from the IEEPA duties paid on eligible entries, not from total import charges, lost sales or a consumer price increase. There is no single payback amount that applies to every importer because the underlying entry payments differ.

Federal law requires the refund of excess deposited duties with interest as determined at liquidation or reliquidation. CBP says its general IEEPA interest calculation runs from the deposit or estimated duty payment through liquidation or reliquidation. The applicable interest rate is determined by the Internal Revenue Service and published quarterly in the Federal Register. Interest therefore varies with the payment dates and the rates in effect; no fixed percentage applies to every claim.

CAPE processing recalculates the entire entry’s applicable duties, taxes and fees, and can produce a bill if the payments fall short of the corrected amount. CBP also applies a refund to outstanding CBP debt and pays any balance that remains. The amount that reaches the bank can therefore be less than the IEEPA duties plus interest.

CBP consolidates refunds by importer of record, or the Form 4811 designee, and by liquidation date. A deposit in the bank may therefore combine multiple entries; compare it with the linked refund records before treating a difference as an underpayment. CBP charges no fee to process these tariff refunds.

Timing depends on the entry, not just the announcement

CBP generally expects a valid refund within 60 to 90 days after accepting a CAPE declaration, unless a compliance concern requires further review. That estimate begins with acceptance, so it should not be counted from the Supreme Court’s decision or from an unsuccessful submission. For an entry that is extended, suspended or under review, CBP says the refund, if validated, is issued at liquidation.

Federal customs law requires payment of a refund within 30 days after liquidation or reliquidation. That statutory payment clock and CBP’s overall processing estimate begin at different events.

As of October 2, 2026, CBP reported approximately $136.6 billion in potential and certified refunds accepted for CAPE processing. Of that amount, about $126 billion in duties and interest had been certified and sent to Treasury for disbursement. Those totals describe stages in processing; they do not show that every included importer has received money in its account.

In its October 6, 2026, court filing, CBP said 6.2 million entries on CAPE declarations had failed its entry checks, mainly because the entry was past CBP’s 90-day reliquidation authority, lacked a Chapter 99 tariff number used to assess IEEPA duties, or had already been filed on an earlier declaration. A rejected entry needs a diagnosis before it is resubmitted, because an older entry, a missing tariff number and a duplicate filing are different problems.

Older entries and disputes may require a court route

On April 17, 2026, the Court of International Trade ordered CBP to liquidate or reliquidate, without regard to the IEEPA duties, entries that had been subject to them, including entries whose liquidation was final. The government appealed to the Federal Circuit, where the broad refund appeal remained pending as of October 8, 2026. That appeal is V.O.S. Selections, Inc. v. Trump, No. 26-1895. For entries outside the first refund phase, CBP offers no legal guidance on whether a court case must be filed.

A July 17, 2026, order captioned In re Tariffs Collected in Reliance on IEEPA, filed in case No. 25-cv-00595, directed CBP to reliquidate, without IEEPA duties, plaintiffs’ entries liquidated more than 80 days earlier. In the separate Freestyle World case, No. 26-cv-01088, CBP reported that CAPE Phase 3 deployed on October 6, 2026, for finally liquidated entries filed by plaintiffs for whom the court had ordered reliquidation. CBP notified plaintiffs whose valid importer numbers were submitted by July 30 that they could now file Phase 3 CAPE declarations, while later submitters would receive further instructions. Phase 3 supplies an operating route for those court-covered plaintiffs; it does not show that every older entry can use the ordinary upload process.

The October 8 opinion says CAPE does not accept finally liquidated entries of nonplaintiff importers. On October 8, the court certified a class in Freestyle World, Inc. v. United States, No. 26-01088, covering importers of record who paid the challenged IEEPA duties from February 1, 2025, through February 19, 2026, except entities that had separately sued to recover them. The opinion says there had been no merits decision in Freestyle and that class members cannot opt in or out.

A customs protest, a formal objection to a Customs decision, generally must be filed within 180 days after liquidation or reliquidation or, where neither applies, after the decision being protested. A liquidation, like the other Customs decisions the law lists, generally becomes final unless a protest is filed or a timely lawsuit contesting a protest’s denial is brought in the Court of International Trade. The protest deadline is a different clock from CAPE’s 80-day window. Missing either one can close a route, so check both dates for each entry. In a March 20, 2026, order, the trade court warned importers about the protest remedies in 19 U.S.C. 1514 because no resolution had been reached for entries whose liquidation had become final. Ask qualified customs counsel before the 180-day deadline whether a protest is needed for the entry.

A protest must identify the importer and entry, the relevant liquidation or decision date, the merchandise, and the specific objection and grounds supporting it. A general demand to recover unlawful tariffs is therefore no substitute for identifying the decision being challenged.

The Court of International Trade has jurisdiction over actions contesting Customs’ denial of a protest. Such a lawsuit generally must begin within 180 days after the denial notice is mailed or after the law treats the protest as denied. A protest-denial action generally also requires payment of all liquidated duties, charges or exactions when the action begins, with a specific exception for sureties.

For an older entry, an open protest or a rejected declaration, have the broker and qualified customs counsel identify the applicable administrative or court route and its deadline.

Watch the next instructions that affect the entry

The October 8, 2026, class-certification order scheduled a closed conference for October 13 at 3 p.m. Eastern and required the parties to submit a proposed schedule by October 22, including a date for the government to respond to the class complaint. These are the next court steps, not a promise that every class member will receive an immediate payment.

CBP directs general IEEPA-refund questions to traderelations@cbp.dhs.gov and technical CAPE questions to IEEPARefunds@cbp.dhs.gov. Check the agency’s current refund instructions against the entry’s status before relying on a description of an earlier rollout.