U.S. importers may now be eligible to recover a portion of previously paid tariffs. On April 20, U.S. Customs and Border Protection (CBP) officially launched Phase 1 of the CAPE refund process following a Supreme Court ruling that certain tariffs collected between February 2025 and February 24, 2026 under the IEEPA framework were improperly imposed.
This marks one of the largest tariff refund programs in U.S. customs history, with an estimated $170 billion potentially eligible for reimbursement.
Importers should note: refunds are not automatic and must be actively claimed.
What Is the CAPE Tariff Refund Program?
The CAPE (Claims and Post-Entry Adjustment Environment) system is CBP’s mechanism for processing IEEPA-related tariff refund requests.
During Phase 1, the program applies to two categories of entries:
- Entries that have not yet been liquidated
- Entries liquidated within the past 80 days
Entries involving antidumping duties (AD), countervailing duties (CVD), or complex trade enforcement actions are currently excluded but may be included in later phases.
How Importers Can Apply for Tariff Refunds
Eligible importers (or their authorized customs brokers) must submit refund requests through the ACE Secure Data Portal.
The process includes:
- Logging into the ACE Secure Data Portal
- Submitting a CAPE Declaration
- Uploading entry documentation
- CBP verification and removal of IEEPA tariff charges
- Recalculation of standard duties
- Issuance of refunds via ACH bank transfer
Approved refunds may include interest payments, depending on processing timelines.
Expected Refund Timeline
Once a claim is accepted by CBP:
- Refunds are typically issued within 60–90 days
- Processing time may vary depending on compliance review requirements
- Incorrect banking details may delay payment
Because submissions cannot be modified after filing, accuracy is critical before final submission.
Important Eligibility Notes for Importers
Before applying, companies should confirm:
- The shipment falls within the eligible time window
- The entry is not subject to AD/CVD restrictions
- ACH payment information is correct
- Supporting entry documentation is complete
Not all IEEPA-related tariffs qualify immediately under Phase 1 coverage.
Why Early Action Matters for U.S. Importers
This refund initiative is expected to generate a significant surge in customs processing activity, which may affect:
- compliance review timelines
- brokerage workloads
- licensing applications
- regulatory approvals tied to U.S. shipping operations
In particular, companies planning to operate on U.S. trade routes should anticipate possible delays in FMC licensing procedures as CBP resources adjust to refund processing volumes.
Applying early helps ensure smoother participation in upcoming U.S. contract shipping seasons.
How We Support Clients During Policy Changes
As an international logistics provider supporting global exporters and U.S. importers, we monitor regulatory updates affecting cross-border trade compliance.
Our team can assist with:
- evaluating shipment eligibility for tariff refunds
- coordinating with customs brokers
- preparing documentation for CAPE submissions
- advising on U.S. route compliance readiness
- planning alternative logistics strategies during policy transitions
