How to Request IEEPA Tariff Refunds
May 2026 | CBP is now accepting requests for eligible IEEPA tariff refunds through its new CAPE process in the ACE Portal. Learn about the process, eligibility, and how you can submit your refund claim.
Tariff Refund Process Released
US Customs and Border Protection (CBP) has opened a new digital process to request refunds for certain duties paid under the International Emergency Economic Powers Act (IEEPA).
If you imported goods subject to IEEPA tariffs in 2025, this update may directly impact your cash flow. Refunds are not automatic, eligibility is limited in early phases, and action may be required to recover duties you’ve already paid.
IEEPA Tariff Refund: Key Highlights
- IEEPA tariffs imposed in 2025 were ruled contrary to law by the US Supreme Court
- CBP is now accepting refund claims for eligible entries
- Refunds are processed digitally through CAPE in ACE
- Approved refunds are paid electronically via ACH
- Phase 1 applies only to a limited subset of entries
What Importers Need to Know about Tariff Refunds
CBP has introduced CAPE (Consolidated Administration and Processing of Entries) within the ACE Portal to manage IEEPA refund requests. CAPE is being rolled out in phases, and eligibility, timing, and documentation requirements are defined by CBP.
For importers who qualify, CAPE provides a structured way to recover duties already paid. UPS can help you understand eligibility, prepare accurate data, and determine the right filing approach based on how your entries were handled.
Importers should note:
- Phase 1 is limited to certain unliquidated entries and certain entries within 80 days of liquidation
- The February 20, 2026, the US Supreme Court decision applies only to 2025 IEEPA emergency tariffs.
- Eligibility, timing, and documentation requirements are defined by CBP and subject to phase‑based limits.
- Refunds are issued only after CBP review and approval and are paid electronically via ACH.
CAPE Phase 1: Which Entries Qualify Today
CBP is deploying CAPE in phases. Not all IEEPA related entries qualify yet. Additional phases are expected, but timing has not been finalized. Each phase expands functionality to support different entry scenarios.
Phase 1 launched April 20, 2026 and applied to:
- Certain unliquidated entries
- Certain entries within 80 days of liquidation
Who Can Submit for CAPE Refund Claim
Customs has explained that CAPE filings may only be submitted by:
- The Importer of Record (IOR), or
- The authorized customs broker that originally filed the entry
Currently, third parties without original filing authority cannot submit CAPE declarations.
How Refunds Are Issued and When to Expect Payment
- Refunds are issued only after CBP review and approval
- Payment is made electronically via ACH by CPB
- Some refunds are issued only after an entry liquidates
- Refunds may be paid to the Importer of Record or a party designated on CBP Form 4811
What Importers Should Do Now
Confirm ACE Access
Ensure you can log into ACE and view relevant entry data.
Verify ACH Information
Accurate banking information is required to receive refunds.
Identify Phase 1 Entries
Focus on unliquidated entries and those within 80 days of liquidation.
Determine Filing Responsibility
Only the Importer of Record or original filing broker can submit CAPE claims.
Prepare Clean, Complete Data
Inconsistent entry or payment data can delay or invalidate claims.
How to Submit for IEEPA Tariff Refunds
IEEPA refunds affect importers differently depending on broker coverage, internal resources, and data readiness. UPS is here to help your company and offers flexible support options, so you can choose the level of involvement that fits your needs.
The process for requesting IEEPA tariff refunds depends on who was listed as the Importer of Record (IOR) and UPS’s role on the entry.
Option 1: If UPS was the Importer of Record
No action is required. UPS will manage the refund process directly with US Customs and Border Protection (CBP) and complete any internal reconciliation as refunds are issued.
Option 2: Customer‑Managed Filing (UPS as Broker)
You prepare and submit CAPE filings
- UPS provides guidance and education upon request
- You submit claims directly through CAPE
- Refunds are paid by CBP via ACH directly once approved
- You manage follow‑ups and error resolution
Self-Submission Resources
Option 3: UPS‑Supported Filing Services
UPS CAPE Solution (UPS Entries Only)
An optional UPS‑supported filing service for a fee, where UPS prepares and submits CAPE filings on your behalf for eligible UPS‑brokered entries.
UPS supports
- Eligibility checks and data remediation, where possible, before CBP submission
- CAPE declaration preparation and submission
- Status monitoring and ACH support
- Non-UPS broker entries are excluded
Customers can get started by completing the UPS IEEPA Refund CAPE Process Request Form, and a UPS representative will follow up with details.
Fill out UPS CAPE Solution Request Form
Sign the 2026 Pricing Schedule Form
UPS® Trade Advisory Services (Multi‑Broker Solution)
If the customer was the Importer of Record and UPS was not the customs broker, UPS® Trade Advisory Services offers support to customers with IEEPA refund filings.
UPS supports
- Reviews ES003 data from customer and provides CAPE template with eligible data only
- Centralized handling of eligibility issues
- Provides support to reduce internal burden
Important considerations
- Eligibility does not guarantee a refund
- Filing before an entry qualifies may result in rework or rejection
- CBP guidance may evolve as additional CAPE phases are introduced
- This information is provided for general awareness and is not legal advice
Complete the UPS® Trade Advisory Services Request Form
Customs Resources
Access official US Customs and Border Protection (CBP) guidance, tools, and resource materials:
Applying for an ACE Secure Data Portal Account | US Customs and Border Protection
ACE Portal - ACH Bank Information for Electronic Refunds
ACE Portal and ACH Refunds FAQs | US Customs and Border Protection
Trade Information Notice: ACE Portal Feature for Trade Users to Add Notify Parties
Customs Refunds FAQs
Quick answers to common questions about potential tariff refunds, PSCs, and customs liquidation.
CAPE (Consolidated Administration and Processing of Entries) is CBP’s new system for managing IEEPA refunds. It is designed to:
- Centralize refund claims and interest
- Replace manual and fragmented refund processes
- Improve consistency and validation
CAPE is being rolled out in phases and currently supports IEEPA refunds only.
Yes. CBP launched Phase 1 of the CAPE refund process on April 20, 2026. Phase 1 launches April 20, 2026.
-
Phase 1 is limited in scope and applies only to:
- Certain unliquidated entries
- Certain entries within 80 days of liquidation
-
More complex scenarios will be supported in future phases.
If ACH enrollment or ACE account information is missing or incomplete, CBP will place the refund into reject status. The refund will not be released until the Importer of Record updates their information and resolves the issue with CBP.
How the Filing Works
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CAPE Declarations are submitted through the web‑based ACE Portal, not through ABI.
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Filers upload a .CSV file using the CAPE tab in ACE.
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Each CAPE Declaration:
- Contains a list of entries requesting IEEPA refunds
- Requires no additional data beyond the entry list
- Can include up to 9,999 entries
-
Multiple CAPE Declarations may be submitted if needed.
What Happens After Submission
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Once a CAPE Declaration is validated and accepted:
- ACE removes the IEEPA Chapter 99 HTS provision
- ACE removes the corresponding IEEPA duties
- An updated version of the entry is created
-
CBP then:
- Reviews the updated entries
- Liquidates or reliquidates, as applicable
-
Refunds are consolidated by IOR, or by the designated refund recipient listed on CBP Form 4811, and tied to liquidation date.
Phase 1 generally includes:
- Unliquidated entries subject to IEEPA duties
- Certain entries that liquidated within a limited timeframe prior to submission
- Certain suspended or extended entries
CBP will address additional entry types in later phases of CAPE.
- Final liquidations outside the current phase
- Entries under reconciliation
- Entries with open protests
- Drawback claims
- Certain AD/CVD entries
-
Most valid refunds are expected within 60–90 days after CAPE acceptance.
-
Refund timing may be extended when:
- Entries are under review
- Entries are suspended or extended
- Entries have not yet liquidated
- Warehouse entries are involved
-
In some cases, refunds will only be issued at liquidation.
Post Summary Corrections are a mechanism for correcting entry data and requesting certain refunds.
- PSCs are not used for IEEPA refunds
- Refunds must go through CAPE only
If validation fails:
- ACE provides an error message
- You can download an Excel file listing the issues
- Common errors include invalid entry numbers, duplicates, or filer code mismatches
- Once corrected, you can re‑upload the file
If UPS was the IOR (regardless of whether the shipment moved under SP or SCS), no customer action is required.
UPS will:
- File directly with US Customs and Border Protection (CBP)
- Manage the refund process through CAPE
- Reconcile refunds internally once issued
- Only the Importer of Record or their authorized customs broker
- Unliquidated entries
- Entries within 80 days of liquidation
- Certain suspended or extended entries
- Final liquidations outside the current phase
- Entries under reconciliation
- Certain AD/CVD entries
- Drawback Claims
- Entries with open protests
- CBP estimates 60–90 days after CAPE acceptance
- Longer if validations fail or liquidation is pending
Customers have two options:
-
Option 1 Self‑service:
Customers may file directly with CBP using the CAPE process. UPS provides guidance on:- Setting up an ACE account
- ACH enrollment
- Understanding CAPE filing requirements
-
Option 2 UPS‑supported filing service (fee‑based):
UPS can assist with preparation and submission of CAPE declarations on the customer’s behalf.
To initiate either option, customers should complete the UPS IEEPA Refund CAPE Process Request Form. A UPS representative will follow up to discuss available services, requirements, and pricing.
If UPS did not act as the customs broker on the entry, UPS® Trade Advisory Services may offer advisory data prep support depending on the customer’s situation. To initiate this process, customers should complete the UPS® Trade Advisory Services Request Form.
Once received, we will review the request and contact the designated customer representative to confirm scope alignment, eligibility considerations, and next steps, consistent with the executed agreement.
- CBP will place the refund into reject status until the Importer of Record updates their information and notifies CBP.
- CBP will not auto-fix banking issues
Disclaimer: At the date of this publication, applicable policies are evolving. This document is for informational purposes only. It does not constitute legal or professional advice. Information herein was obtained from government, industry, and other public sources which are subject to change and have not been independently verified by UPS. Recipient has sole responsibility for determining the usability of any information provided herein. Before recipient acts on the information, recipient should seek professional advice regarding its applicability to the recipient’s specific circumstances.
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