You are only eligible for a refund if you directly paid tariffs applied under the International Emergency Economic Powers Act (IEEPA). To find out if you qualify, start by reviewing your import entry paperwork filed with U.S. Customs and Border Protection (CBP). On CBP Form 7501, look at the Harmonized Tariff Schedule of the United States (HTSUS) classification number, specific program indicators (SPI), and duty lines. If IEEPA tariffs were applied, they should show up as an additional duty line tied to a specific tariff action, specifically under Chapter 99 of the HTSUS.
Refunds are not available for Section 232, Section 301, Section 201, anti-dumping and countervailing duties, or most-favored nation tariffs. If you are unsure whether you directly paid IEEPA tariffs on imports, ask your customs broker or review your records in the Automated Commercial Environment (ACE) portal.
FEDERAL COURT ORDERS
On March 4, 2026, Judge Richard Eaton of the U.S. Court of International Trade issued an order in Atmus Filtration, Inc. v. United States requiring the federal government to begin processing refunds for tariffs imposed under IEEPA. The ruling followed the U.S. Supreme Court decision that invalidated IEEPA tariffs. For small business owners, this means that if you directly paid IEEPA tariffs on imported goods, you may be eligible for a refund. CBP has stated that, due to existing technology limitations, internal processes, and staffing capacity, additional time is needed to update its systems prior to issuing refunds. Accordingly, the court ordered CBP to provide regular progress reports documenting the agency’s efforts toward implementing the refund process.
WHAT IS THE REFUND PROCESS?
In a progress report filed in court on March 12, 2026, CBP indicated that it will utilize a tool known as CAPE— Consolidated Administration and Processing of Entries— to process refunds in bulk. CAPE is expected to:
- Allow importers to upload a CSV file listing affected entries;
- Recalculate entries excluding IEEPA tariffs;
- Review and establish liquidation and refund dates; and
- Issue electronic payments directly to the importer’s bank.
This four-part system, operated through an online claims portal, is how CBP will coordinate refunds of potentially $166 billion in IEEPA tariff collections, plus interest. CBP’s refund claims portal is expected to be operational by April 20, 2026.
If you directly paid IEEPA tariffs on imports and are eligible for a refund, you must enroll in ACH through CBP’s ACE Portal to receive payment once CBP’s refund process is finalized.
For additional information and guidance regarding tariff refunds and eligibility requirements, watch the Legal Center’s webinar: What the Supreme Court’s tariff decision means for small businesses—and could you get money back?