A recent Supreme Court ruling determined that certain tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were not authorized. U.S. Customs and Border Protection (CBP) has started implementing a refund process. WonderTrust helps businesses identify potential refund exposure, organize import data, and coordinate the submission process through CBP’s system.
Beginning in 2025 and continuing into 2026, the U.S. government imposed tariffs on certain imported goods under authority claimed through the International Emergency Economic Powers Act (IEEPA). These tariffs affected businesses across a range of industries and created significant additional import costs.
A group of importers challenged the legality of these tariffs in federal court, arguing that the administration exceeded the authority granted under IEEPA when imposing global tariffs. On February 20, 2026, the U.S. Supreme Court ruled in Learning Resources v. Trump that the administration did not have authority to impose global tariffs under IEEPA.
The decision addressed the legality of the tariffs. Following that decision, on March 4, 2026, the U.S. Court of International Trade directed U.S. Customs and Border Protection (CBP) to remove certain IEEPA duties from affected import entries and begin implementing a refund framework.
CBP has since introduced an initial filing process through the CAPE (Consolidated Administration and Processing of Entries) system, which is expected to go live on April 20, 2026.
CBP introduced an initial administrative process for issuing IEEPA tariff refunds through the CAPE system within the ACE Portal.
The first phase is expected to go live on April 20, 2026 and will allow for submission of refund claims for certain eligible entries, including unliquidated entries and entries within a limited window of liquidation.
Additional phases are expected to expand the process to more complex scenarios, including entries that have already reached final liquidation.
Businesses that imported goods into the United States during the period when IEEPA tariffs were in effect may be eligible for refunds. Because tariff payments are tied to specific import entries and classifications, eligibility depends on the details of each individual import transaction and its current status within CBP’s system.
In many cases, the importer of record listed on the customs entry is the party responsible for the tariff payment. Importers that worked through brokers or logistics providers may need to coordinate with those parties to gather entry-level data.
CBP has introduced an initial administrative process for IEEPA tariff refunds through the CAPE (Consolidated Administration and Processing of Entries) system within the ACE Portal. The first phase of this process is expected to go live on April 20, 2026 and will allow eligible import entries to be submitted for review and refund.
Import duties are finalized through a process known as liquidation, which occurs after CBP completes its review of an import entry.
Entries that have not yet reached final liquidation or are within a limited post-liquidation window may be eligible for adjustment through the current CAPE filing process. Entries that have already reached final liquidation are not fully addressed under the initial CAPE phase and may require additional administrative or legal steps as future phases of the process are implemented.
Refund claims are submitted through the CAPE system within the ACE Portal. Once submitted, CBP removes IEEPA tariff classifications, recalculates duties, and processes refunds, typically including applicable interest.
The current process requires identifying eligible entries, preparing submission data, and coordinating with the appropriate filing party. While CBP performs the calculation of refunds, the accuracy and completeness of the submission can impact timing and outcomes.
Refunds are issued electronically through the ACE Portal. Importers must have ACH (Automated Clearing House) refund information set up within their ACE account in order to receive payment. Businesses may need to coordinate with their broker or internal team to ensure this is properly configured before submission.
Businesses that may be eligible should begin organizing import and tariff records now to support CAPE refund submissions. Having documentation readily available can significantly speed up the filing process and reduce delays once claims are submitted.
In many cases, this information is held across multiple systems or third parties and may require coordination with customs brokers or internal teams to compile.
WonderTrust works alongside your team and customs broker to identify eligible import entries, organize documentation, and support the submission of IEEPA tariff refund claims through the CAPE system.
Exposure Assessment
We evaluate your import activity and broker relationships to identify potential IEEPA tariff exposure and determine where refund opportunities may exist.
Advisor Review
A WonderTrust advisor reviews your import profile and outlines how the current CAPE process applies to your business, including which entries may be eligible under the initial filing phase.
Data Collection & Organization
We assist in gathering and structuring import data — including entry summaries, broker reports, and internal records — to support accurate identification of eligible entries.
Filing Coordination
We help prepare submission-ready data and coordinate with your customs broker or authorized filer to support CAPE refund submissions.
While CBP performs the calculation of refunds, the identification of eligible entries and coordination of the filing process can be complex — particularly for businesses with multiple brokers or high import volume.
Businesses that imported goods during the IEEPA tariff period may be eligible for refunds through the new CAPE filing process. Complete a short assessment to identify potential exposure and next steps.
CONTEXT
The IEEPA tariff refund process is being implemented by U.S. Customs and Border Protection (CBP) and continues to evolve, including through the phased rollout of the CAPE system. Eligibility for and availability of refunds will depend on the specific facts of each business’s import activity, including entry status, documentation, and applicable administrative procedures. WonderTrust is an independent advisory firm and is not affiliated with any government agency. This Website is for general informational purposes only and is not legal or tax advice.