IEEPA Tariff Refunds: CBP Outlines Claims Process

Importers Will be Required to Submit Claims for Refunds Under CBP Proposal

United States Customs and Border Protection (CBP) in a filing before the U.S. Court of International Trade submitted on March 12, outlined the process they intend to implement for IEEPA tariff refunds. The proposal applies to the more than $130 billion in tariffs CBP collected without legal authority. 

This filing is a reponse to the United States Supreme Court ruling in Learning Resources, Inc. v. Trump, Nos. 24‑1287 & 25‑250 (U.S. Feb. 20, 2026) that the Trump Administration did not have authority to issue tariffs under the International Emergency Economic Powers Act (IEEPA). 

Claims to be Filed Through “CAPE” System

CBP is developing a new system called CAPE – Consolidated Administration and Processing of Entries to prepare to return IEEPA tariff refunds to importers. CAPE will contain a claims portal for importers to file refund claims. CAPE will be accessibly only through the CBP ACE Portal.

Importers will be able to upload a CSV file containing all entries for which they are claiming Trump tariff refunds. CBP will validate that (1) the submitter of the refund request is the importer of record of the entries or customs broker who filed them and (2) confirm that the entry numbers submitted correspond to valid entry numbers that were assessed IEEPA tariffs.

After validation CBP will process the entries and remove the IEEPA duties as being owed from the entry.

Next CBP will liquidate or reliquidate the entries and refund the payment of IEEPA duties plus interest to the importer of record’s bank account or another person the importer of record has duly authorized under CBP Form 4811 to receive the refunds.

What Steps do Importers Need to Take to Ensure they Receive IEEPA Tariff Refunds?

1. Prepare a list of your entries subject to IEEPA tariffs.Importers should review and identify entries that were subject to IEEPA tariffs.
2. Calculate the refund amount due per entry including interest. Importers should calculate the amount of tariff due to be refunded including interest based on the quarterly IRS interest rate.
3. Determine if you authorized another party to receive your refunds. Over the past year many importers have given third parties authority to receive tariff refunds on their behalf via signing CBP Form 4811 –  “Special Address Notification.” The designation may be based on a per entry or blanket basis. Identify the parties, if any.
4. Revoke/change third-party authority if desired. If your preference is to receive the funds directly or have them deposited in an account of a person who owes you a fiduciary duty (e.g. your attorney), contact CBP and revoke/amend the 4811 designations as appropriate.
5. Ensure you are set up to receive refunds directly from CBP if desired. Refunds are only being paid electronically through the account specified to CBP in the ACE portal. Ensure the correct account information is provided to CBP.

Please contact Erik Lieberman at erl@liebermanpllc.com or 202.830.0300 if you have any questions.