How to File for an IEEPA Tariff Refund: A Step-by-Step Guide for Small Retailers

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Last updated April 11, 2026 — by AmyFay Chandler

If you’re reading this, you’ve probably figured out two things in the last 24 hours: the tariffs you’ve been paying for the last year are getting refunded, and nobody is going to walk you through how to actually claim that money. Both are true. Let me help with the second part.

I represent a dozen brands in Tennessee and Kentucky and two brands nationally. For the last fourteen months I’ve watched my brands and my retailers absorb the cost of these tariffs. Now the Supreme Court has ruled that the IEEPA-based tariffs were imposed without proper authority, and U.S. Customs and Border Protection is opening a refund portal on April 20, 2026 so importers can get their money back — with 6% interest accruing on every dollar you’re owed.

This guide is for the importer of record who’s never filed a customs protest before, doesn’t have a corporate trade attorney on retainer, and just wants to know what to do this week.

Not sure if you’re eligible? Take 90 seconds with the Tariff Refund Eligibility Checker — it’ll tell you whether you qualify before you spend an hour on this article.

What you can actually claim

The CBP refund window only covers tariffs imposed under the International Emergency Economic Powers Act (IEEPA). In practice, that means:

  • The “reciprocal” tariff line items (the ones tied to country-specific retaliation)
  • The “fentanyl” / “trafficking” tariff line items (imposed under the emergency declaration)
  • The “baseline” tariff line items added under the same emergency authority

These are the duties the Supreme Court struck down. They show up on your CBP Form 7501 entry summaries as line items with those exact words in the description, or with HTSUS codes that customs brokers can identify.

What you cannot claim through this portal:

  • Section 232 tariffs (steel, aluminum, autos) — these were imposed under different legal authority and are still in effect
  • Section 301 tariffs (China-specific) — same story, different statute, still standing
  • Standard MFN duty rates — these were never in dispute

If you only paid Section 232 or 301 duties, you’re not part of this refund window. There are separate court challenges working through the system for those, but they’re not at the refund stage yet.

The five steps

Step 1: Set up your ACE Portal account right now

This is the detail nobody mentions until you need it: the ACE Portal account takes three to four weeks to set up. It’s not instant. CBP has to verify your business identity, your importer of record number, and tie your account to your customs entries. If you wait until April 20 to start this process, you’re going to be sitting in a queue while interest accrues without you.

Go to ace.cbp.gov and click “Sign Up.” You’ll need:

  • Your business EIN
  • Your importer of record number (the same number on your customs entries — your customs broker has this)
  • A trade account administrator (this can be you, the owner)
  • Proof of your business identity (articles of incorporation or equivalent)
  • An email address you actually monitor

Submit and wait. CBP will email you a verification link, then a second email with your Trade Account ID. The account becomes fully usable in 15-20 business days.

If you’ve never imported before, you don’t need an ACE account — you wouldn’t have paid IEEPA tariffs in the first place.

If you import through a customs broker, your broker likely already has an ACE account that lists your business as a client. Ask them whether you should set up your own or use theirs. For small refund claims, using the broker’s account is often easier and faster.

Step 2: Pull your CBP Form 7501s for the entire eligible period

The 7501 is the “Entry Summary” — the form CBP issued for every customs entry you made between February 1, 2025 and now. You need every single one of them to support your refund claim.

Where to find them:

  1. From your customs broker. Email them and say: “Please send me copies of every CBP Form 7501 you filed on our behalf from February 2025 through today.” Most brokers will send these as a single ZIP file or a shared folder. Some charge a small retrieval fee. Most don’t.
  2. From your own ACE account, once it’s active. ACE archives every entry under your importer number — but only after your account is set up and verified.
  3. From your bookkeeper or controller, if they downloaded copies at the time of entry.

If you used a customs broker and they no longer exist (mergers, retirements happen), you can request copies directly from CBP using a Freedom of Information Act request — but that takes months. Start with the broker first.

Step 3: Identify which line items are IEEPA-coded

Open every 7501 and look at the duty line items. You’re hunting for any line that says:

  • “IEEPA”
  • “Reciprocal Tariff”
  • “Fentanyl”
  • “Trafficking”
  • “Baseline” (when paired with an emergency authority code)

Add up the dollar amounts of all the qualifying line items. That’s the rough size of your refund.

This is where most small importers get tripped up. Your 7501 will have a mix of duty types — Section 301 China duties, Section 232 steel duties, IEEPA reciprocal duties, and standard MFN rates — all on the same form. You only get to claim the IEEPA portion.

If your customs broker is helpful, ask them to mark up your 7501s with which line items qualify. They can do this in twenty minutes for an entire year of entries. If you have to do it yourself, expect to spend a couple of hours with a highlighter and a calculator.

Step 4: File your CAPE Declaration (April 20 onward)

CAPE stands for Consolidated Administration and Processing of Entries — the refund tool CBP is launching inside ACE on April 20, 2026. Here’s what filing actually looks like, based on CBP’s published CSMS guidance:

Important Phase 1 caveat: the April 20 launch is limited to certain unliquidated entries and entries within 80 days of liquidation. More complex cases — older entries that have already liquidated, complicated protest histories — will be handled in later CAPE phases CBP hasn’t yet scheduled. Check your 7501 dates before you file to make sure your entries qualify for Phase 1.

  1. Log into ACE at ace.cbp.gov.
  2. Navigate to the new CAPE module inside your ACE Secure Data Portal.
  3. Prepare a CAPE Declaration as a CSV file listing your eligible entries. CBP’s CSMS bulletin has the exact CSV format specification — your customs broker can also prepare this for you.
  4. Upload the CSV through ACE.
  5. CBP reviews the Declaration for acceptance.
  6. You receive confirmation and a tracking reference.

CBP has stated that valid IEEPA refunds will generally be issued 60 to 90 days after the CAPE Declaration is accepted, with 6% interest accruing on every dollar from the date of original payment, unless a compliance concern kicks off further review.

Realistic timeline: file in late April, expect refund in July for straightforward claims. More complex cases take longer. Earlier filers get processed first, so the ACE account setup head start matters.

Step 5: Follow up if you don’t hear back in 60 days

CBP is going to be processing thousands of these claims. Things will get lost. Things will sit in queues. After 60 days from filing, if you haven’t received an acknowledgment with a tracking number, log back into ACE and check your protest status. If it shows “pending review” or no status at all, file an inquiry through the ACE help desk.

Don’t refile. Duplicate claims slow processing for everyone, including you.

What if I bought from a US distributor and didn’t import directly?

You probably can’t file directly — the importer of record (the company on the customs entry) is the one who gets the refund. But that doesn’t mean you’re out of luck.

Tariff costs were almost certainly passed through to you in higher wholesale prices. Now your suppliers are about to receive refunds on costs you helped pay. Email your top five suppliers right now and ask:

“Are you filing for IEEPA tariff refunds when CBP’s CAPE portal opens April 20? If so, what’s your plan for sharing those refunds with your wholesale customers — through credits, lower pricing going forward, or anything else?”

This is a fair question and a reasonable one. Some suppliers will give you a clear answer. Some will dodge. The ones who dodge are the ones to watch — they’re going to pocket the refund and hope you don’t notice.

Common questions

Do I need a customs attorney?
Probably not, unless your refund is over $50,000 or you have a complicated history of protests. For most independent retailers, the CAPE portal is designed to be self-service.

What does the 6% interest actually mean?
If you paid $20,000 in IEEPA tariffs in March 2025 and CBP issues your refund in September 2026, you’ll receive your $20,000 plus roughly $1,800 in interest. The interest accrues daily from the date of original payment.

What if I no longer have the records?
Your customs broker is your best path. If you can’t reach them, file a FOIA request with CBP — they keep all entry records for ten years.

Can I file for entries from before February 2025?
The IEEPA refund window only covers entries made under the emergency declaration that was struck down. For entries before that, the underlying authority is different and isn’t part of this refund.

My business is closed or I sold it — can I still file?
If you were the importer of record at the time of the entries and you have the documentation, yes — but the legal mechanics get more complicated. This is one of the cases where a customs attorney is worth the consult.

The honest truth

If you only have a handful of entries and a small refund coming (under $2,000), the time investment may not be worth it. Three hours of your time is also worth real money.

If your refund is in the five figures, stop reading this article and go set up your ACE account. The interest clock is running.

If you’re somewhere in between, the calculus is simple: a customs broker will usually file for you for $200-$500, and most will only take the work if your refund is large enough to make their fee worth it. That’s a useful filter — if a broker won’t take your case, your refund probably isn’t large enough to justify your own time either.

One last thing

On April 20 I’m going to be watching the CAPE portal launch in real time — brand contacts filing on day one, tracking what’s breaking, where the queue is, what the CSV format actually wants. I’ll send a live update the moment it goes live.

If you want that update — and the Morning Retail Tidbit each weekday, one short paragraph on what’s happening in independent retail — drop your email below. I write this stuff because nobody else is, and because every retailer in my book over the last decade has had to figure out something hard alone. If I can save you an hour of that, this is worth it.

Send me the live launch update →

xoxo,
AmyFay


This guide is general information, not legal or customs advice. For high-value claims or complex situations, consult a licensed customs broker or trade attorney. Rules change — verify with CBP before filing.

P.S. If you’re not sure whether any of this applies to you, run the Tariff Refund Eligibility Checker first. Ninety seconds, four questions, clear answer.