Still waiting on your IEEPA tariff refund? This IEEPA Tariff Refund Update explains the latest developments and the steps importers should take to protect their claims. In September 2026, CBP announced that Phase Three of the CAPE IEEPA refund process will launch on October 6, 2026. Importers should review whether their entries may qualify and what steps they should take to protect their refund rights.
If you’re an importer and your goods were hit with IEEPA tariffs, you may be wondering:
Have I missed my opportunity to request a refund?
Why haven’t I received my refund yet?
Are there any new developments in the refund process?
Should I be doing something now?
If your company paid IEEPA tariffs, now is not the time to assume everything will work itself out. Whether you have already submitted refund requests or have not yet taken action, there are several important steps you should consider to protect your rights and maximize any potential recovery.
Have I missed my opportunity to request a refund?
Many importers mistakenly believe that once the court issued its decision, refunds happen automatically.
Or they are simply overwhelmed by the complexity of the process. Either way, it may not be too late to file and trusted advisors can help!
Depending on the status of your entries, you can likely still file your refund claim through CBP’s ACE portal.
If your entries have timed out of Phase One (their liquidation dates are more than 80 days beyond the current date), you still have a chance to recover the tariffs in a future phase, but you must protect your right to a refund through protest and/or legal action.
The first step is understanding which entries may still be eligible for a refund.
Review Every Entry That Included IEEPA Duties
Start by reaching out to a trusted advisor that can help you gain access to your ACE account, compile the entry data necessary for your claim, enter your banking details into ACE and submit a claim for your refund.
If your entries have timed out of Phase One, experts can help you decide whether protests and/or legal action may be warranted to protect your right to a future refund.
Don’t leave money on the table! Dimerco’s team of compliance experts can help walk you through the steps to ensure you recover what’s owed to you.
Don’t Ignore Protest Deadlines
The most important date is not the date of your entry. It’s the deadline for challenging a specific customs entry, or 180 days after the date of liquidation.
If you were unable to file your Phase One claim, and your entry is already more than 80 days past liquidation, it’s important to file a protest to keep your entry open for a future IEEPA refund claim before the 180 day timeline expires.
If a protest deadline expires before appropriate action is taken, refund opportunities may be more limited.
Keep importers’ refund claims alive while courts remain open and authorities are approached.
The launch of CAPE Phase Three does not eliminate the need to monitor protest and litigation deadlines. Importers with entries outside the current CAPE eligibility criteria should continue taking appropriate steps to preserve their potential refund rights.
Why haven’t I received my refund yet?
If you already filed your refund claim, keep monitoring your claims using CBP’s recommended ACE reports (the Rev-603, Rev-613, Rev-615 and Es-022 reports) until you’ve received 100% of the tariffs owed back to you.
Using CBP’s recommended ACE reports, you can track the status of your refunds and their liquidation or reliquidation dates.
Generally, refunds are transmitted to the Department of the Treasury 14 to 16 days after CBP removes the IEEPA tariffs from the entry and liquidates or reliquidates the transaction.
This transmission date is known as the Refund Date on CBP’s ACE reports mentioned above. The funds are then transmitted to the importer within a couple of business days of the Refund Date.
Common reasons your refund may be delayed
If your ACE CAPE reports indicate the refund has already been issued, but you haven’t received the funds, there are several possible reasons. Here are some examples along with best next steps for each:
1.) Your refund may have been sent to your Customs broker. If you signed a 4811 directing your refund to your broker, it is very possible that CBP issued your ACE reports and that your party is listed in the Notify Party field in your ACE account, your refund was likely mailed to that party/broker.
Reach out to them to track your refund. They are legally obligated to send you an accounting of refunds received on your behalf and to return the funds to you (potentially minus any money you currently owe them).
2.) Your refund may have been used to offset an open Customs bill. If your refund was diverted to an open Customs bill, you’ll see this note in the Secondary status column in your ACE reports.
3.) Your refund may have been diverted to a state or federal agency to pay an outstanding tax bill. That may or may not be known to you. In this case, reach out to CBP at [email protected] or [email protected] to learn where your refund was routed.
4.) Your refund may have been rejected because your banking information is missing or inaccurate in ACE. If this is the case, you’ll see your refund listed on the ACE Rev-013 report. If you see a refund on this report, you can update your banking information in ACE and then email CBP at [email protected] to ask them to reissue the refund.
5.) There are, of course, other reasons for a missing refund. Reach out to your trusted advisor who can help you. ACE reports include dates the money went to you.
If your ACE report includes the refund but you still haven’t received it, or if you’re having difficulty interpreting the reports, reach out to a trusted advisor for help. Ultimately, you may need to contact CBP for more information at [email protected].
Are there any new developments in the refund process?
Yes. CBP continues to roll out the IEEPA refund process in phases, and a significant new development affects importers with entries that were not covered by the initial CAPE phase.
Phase Three of the CAPE IEEPA refund process is scheduled to launch on October 6, 2026. Under the current requirements, importers must meet both of the following conditions to be eligible for Phase Three:
- Have a valid case on file at the U.S. Court of International Trade (CIT); and
- Have submitted their Importer of Record (IOR) number to CBP by July 30.
CBP has indicated that importers that filed a CIT case or submitted their IOR information after July 30 will receive separate instructions regarding the refund filing process.
For importers without a case currently on file at the CIT, the path for recovering IEEPA duties on fully liquidated entries remains less certain. Importers may consider filing suit to preserve a potential refund claim while the courts continue to address broader questions surrounding refund eligibility.
Importers generally have two years from the date of injury to file suit at the CIT, meaning the filing window could extend into early 2027 depending on the circumstances.
If you have IEEPA-affected entries that were not covered by earlier CAPE phases, now is a good time to confirm your CIT filing status, IOR submission status and which entries may fall within Phase Three.
Should I be doing something now?
Yes! Stay current on legal developments for your refunds that were not covered in Phase One or Phase Two of the IEEPA claims process.
The legal landscape surrounding IEEPA tariffs continues to evolve. Appeals, court rulings, and new CBP guidance could affect refund procedures, eligibility, and timing. Importers should monitor developments closely rather than assuming the current process will remain unchanged.
If you haven’t filed your refund yet
- Check your CAPE Phase Three eligibility. Confirm whether you have a valid CIT case on file and whether your Importer of Record number was submitted to CBP by the July 30 deadline. If either occurred after July 30, watch for additional CBP filing instructions.
- Don’t wait! Reach out to a trusted advisor today for help.
- Regularly check that your ACH Refund Account enrollment is active in ACE and the banking information listed is correct.
If you’ve already filed your claim
- Track liquidation dates carefully on entries that did not qualify for the first or second phase of refunds and preserve your right to a refund through protest and/or legal action.
- Track liquidation for CAPE-filed entries if you have any additional changes you need to make through a post-IEEPA refund protest within the 180-day window.
- Ensure you’ve checked the Claim Status tab for your CAPE filing and resolve any entries in error status with your broker or CBP.
- Refile CAPE claims for any entries that were rejected but have since been corrected.
- Track your refunds using the CBP-recommended CAPE reports. Be sure you’ve received the refunds owed to you and investigate any discrepancies between the refund amount paid and the amount you believe is due.
- Monitor CAPE developments. Phase Three is scheduled to launch October 6, 2026, but additional guidance is still expected for importers that do not meet the current Phase Three eligibility requirements.
Protect your future refund opportunities
- Maintain entry-level documentation for all entries in case CBP requests additional information.
- Verify that the refund amount received matches the total amount shown in your refund reports.
- Begin tracking your Section 122 tariffs. No action is necessary yet, but the refund process may follow a similar path if those tariffs are later ruled unlawful.
- Review the Notify Parties tab in ACE to ensure there are no outdated Form 4811 authorizations that could divert refunds to a third party.
- Protect your refunds and ACH Refund Account information by removing ACE access for employees or third parties who have left your company or no longer require access.
Don’t Miss Your Refund Opportunity
The situation surrounding IEEPA duties is still evolving. Companies that have paid these tariffs should take action quickly and should not assume that refunds will occur without monitoring and follow-up.
With CAPE Phase Three scheduled to launch October 6, importers should review their eligibility now, including their CIT filing status and IOR submission status, and identify any entries that may require additional action.
Because litigation is not over, if your company paid IEEPA tariffs and you’re unsure whether you’ve taken every step necessary to recover 100% of the money owed to you, now is the time to take action to protect your refund rights.
A proactive assessment today may preserve opportunities that could benefit your company tomorrow.
