The four refund routes
| Entry status | Route | Typical timing |
|---|---|---|
| Not liquidated | CAPE declaration filed in ACE (CSV upload, up to 9,999 entries) | About 60–90 days after the declaration is accepted |
| Liquidated within the last 80 days | CAPE Phase 1 | About 60–90 days |
| Liquidated 81–180 days ago | Formal protest under 19 U.S.C. 1514, before day 180 | 6–18 months |
| Liquidated over 180 days ago (final) | Court of International Trade, or a later CAPE phase if the courts allow it | 12–24 months or more |
Source: IEEPA refund guide, 2026 and reporting of 22 September 2026. About $166 billion was collected under IEEPA; roughly $107 billion in refunds had been certified by 21 August 2026 (Penn Wharton Budget Model).
What to have ready
- ACE portal access for the importer of record, with verified bank details for ACH refunds
- An entry-level report showing entry date, liquidation date and the IEEPA duty lines (Chapter 99 headings)
- A customs broker or trade attorney for protests and anything already final
Frequently asked questions
Who can claim the refund?
The importer of record that paid the duty. If a supplier or freight forwarder was the importer of record and passed the tariff on to you in the price, your recovery is a commercial matter with them, not a CBP refund.
What if an entry isn't liquidated yet?
It can go into a CAPE declaration. Entries usually liquidate about 314 days after entry, so an old entry with no liquidation date should be checked in ACE; it may have liquidated since your report was run.
Is the 180-day protest deadline strict?
Yes. A protest must be filed within 180 days of the liquidation date. After that the liquidation is final and the remaining route is litigation, which usually only makes sense for larger amounts.
Is my data uploaded?
No. The sorting happens in your browser. Nothing you paste is sent anywhere.