Customs

Tariff refunds: what importers can claim back and by when

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QUICK ANSWER IEEPA tariff refunds are live. The Supreme Court ruled the IEEPA tariffs unlawful in February 2026, the Court of International Trade ordered the money returned, and CBP has been paying through its CAPE process since April, about 23 billion dollars approved in the first phase alone. Whether you get yours depends on one thing above all others: the liquidation status of the entries you paid on. Unliquidated entries are the easy case. Entries that have finally liquidated are the hard one, and for those the door closes at the end of January 2027.

IEEPA tariff refunds are the largest refund event US importers have seen, and a lot of the money is still sitting with importers who have not checked their own entries. Below is what happened, which entries qualify, how the claim runs, and the dates that decide whether you are inside or outside.

What happened and why there is money to claim

The tariffs imposed under the International Emergency Economic Powers Act were struck down. Everything since has been about how the money gets back to the importers who paid it, on top of the duty they still owe on the ordinary rate.

The refund timeline

Date What happened
February 2026 The Supreme Court rules in Learning Resources v. United States that the IEEPA tariffs were unlawful
Shortly after The Court of International Trade orders refunds to all importers of record, with compliance partly stayed while CBP builds the process
20 April 2026 CBP opens CAPE Phase 1 for unliquidated entries and entries liquidated within 80 days
3 June 2026 The Department of Justice appeals to the Federal Circuit, arguing refunds should not extend to importers who never filed suit
9 June 2026 About 23 billion dollars approved under Phase 1
29 June 2026 CAPE Phase 2 opens for reconciliation and AD/CVD entries, estimated at 28.7 billion dollars
Late July 2026 CAPE Phase 3 opens for finally liquidated entries, but only for importers who filed suit at the CIT

Read the last two rows together and the shape of the problem appears. If your entries are still open, the process is built for you. If they closed and you never filed anything, CBP's position is that you are not eligible unless a court says otherwise.

Which of your entries qualify

Liquidation is the point where CBP finalizes the duty on an entry. Most entries liquidate around 314 days after release, and everything about refunds hangs off that clock.

Where each kind of entry stands

Entry status Refund route Difficulty
Unliquidated CAPE declaration through ACE Straightforward, this is what Phase 1 was built for
Liquidated within the last 80 days CAPE declaration Straightforward if you move now
Liquidated, within 180 days of liquidation Protest with CBP Doable, but the 180 day clock is hard
Finally liquidated, no protest, no suit Only through the courts Hard. CBP's position is that you are not eligible without a court order

The first job is not filing anything. It is pulling your entry list for the period you paid IEEPA duties and sorting it into those four buckets. Most importers have entries in more than one.

How a refund claim actually runs

The mechanism is a CAPE declaration submitted through the ACE portal by whoever files your entries. What you need to have ready is ordinary paperwork, and the delay is almost always in finding it rather than in filing it.

You need the entry summaries, the CBP Form 7501 for each entry, proof that the duty was actually paid, and the records from whoever handled the filing. Once a declaration is accepted, refunds have been coming through in about 60 to 90 days, unless something on the entry triggers a closer look.

The part importers underestimate is scope. It is not one claim, it is one line per entry across every entry you filed in that window. The value is in the total, and no single entry looks worth the trouble on its own.

The deadlines that cannot be moved

Two dates matter more than everything else on this page.

180 days from liquidation to file a protest on a liquidated entry. CBP cannot extend it and does not make exceptions. Every week you wait, entries at the back of your list cross that line and stop being recoverable through the ordinary route.

End of January 2027 to file suit at the Court of International Trade for entries that have finally liquidated. After that the entries are closed for good, whatever the appeal decides.

If your entries are still open, neither date bites yet, and that is exactly why they get missed. Entries liquidate on their own schedule, and nobody sends a warning the week before.

What the appeal could still change

The government appealed on 3 June 2026, arguing that the refund order should not cover importers who never went to court themselves. If that argument wins, the practical result is a split: importers who filed protective claims keep their refunds, and importers who waited for the money to arrive on its own may not get it.

That is the whole case for acting now rather than watching it. Filing a claim you turn out not to have needed costs you paperwork. Skipping one you did need costs you the entire amount.

The next refund case worth watching

The same pattern is already running again. The Section 301 forced labor tariff of 10 to 12.5 percent, in force since 24 July 2026 across goods from 60 economies, was challenged at the Court of International Trade on 3 August 2026 by 25 states, which asked the court to block it and to refund what has been paid.

Nobody knows how that one ends. What is already clear is that if refunds are ordered, they will go to importers who can document what they paid, entry by entry, on the same evidence the IEEPA claims needed. Keep those records clean from now, not from the day of the ruling. Current exposure by list is in our Section 301 guide.

How Platton helps with tariff refunds

Pulling the entry list

The first step is a list of every entry in the affected window with its liquidation status. If Platton moved the freight, that data is in the file. If another forwarder did, the entry numbers still come off your own records and we can work from those.

Sorting entries by route

Each entry falls into one of the four buckets above, and the route is different for each. Sorting them tells you what is recoverable, what is urgent and what needs a lawyer rather than a filing.

Getting the paperwork together

Entry summaries, proof of payment, and the filing records. This is the part that takes the time, and it is the part we can do while the deadlines are still comfortable.

Keeping the next set clean

On current shipments, the entry records that a future refund would need are kept complete from the start, which costs nothing now and is the difference between claiming and not claiming later. Our customs clearance work runs that way as standard.

Common Questions About Tariff Refunds

Who gets the IEEPA tariff refund, the importer or the forwarder?

The importer of record. The duty was paid in your name against your entry, so the refund goes back to you, not to whoever arranged the shipping or filed the paperwork. If a third party paid the duty on your behalf, the money still flows through the importer of record, which is why your own entry records are what the claim rests on.

How long does a tariff refund take once the claim is in?

Refunds under the CAPE process have been arriving roughly 60 to 90 days after the declaration is accepted, where nothing on the entry raises a question. Entries with compliance issues, valuation questions or AD/CVD exposure take longer because CBP reviews them before releasing money. The 60 to 90 day window starts at acceptance, not at submission.

What if my entries have already liquidated?

Then your route depends on how long ago. Within 180 days of liquidation you can still protest. Beyond that, CBP's position is that a finally liquidated entry is not eligible unless a court orders otherwise, which is why importers with older entries have been filing at the Court of International Trade to preserve the claim. That door closes at the end of January 2027.

Do I need a lawyer to claim a tariff refund?

Not for the ordinary route. A CAPE declaration on an unliquidated entry is a filing, not litigation, and it runs through the same channel as any entry correction. Finally liquidated entries are different, because preserving those claims has meant filing suit at the CIT, and that is legal work. The split is liquidation status, not the size of the refund.

Will the Section 301 forced labor tariff be refunded too?

It is under challenge at the Court of International Trade, filed by 25 states on 3 August 2026, and no ruling has come. If refunds are ordered, the evidence needed will be the same as for IEEPA: entry summaries and proof of payment, entry by entry. That is an argument for keeping records complete now rather than reconstructing them later.

Section 301 tariffs: current lists, rates and who is covered.

Customs clearance process: entry, release and what happens when CBP holds a shipment.

Duty drawback: recovering duty on goods that leave the country again.

Landed cost: where duty sits in the total cost of an import.

Find out what you are owed

Send your entry numbers for the period you paid, or your importer of record number, and you get back a list of which entries are still open, which are inside the protest window and which need a different route.

Request an entry review

Written by

Max Kershnitskii

Operations Manager at Platton

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