Last reviewed: September 28, 2026. Reading time: about 11 minutes.
Most importers who miss out on tariff refunds do not miss out because they were ineligible. They miss out because nobody checked. Somewhere in a broker portal or an old spreadsheet sit entries that may still be claimable, and the window for some of them is closing.
This checklist takes about 15 minutes. You tick what applies, read what your ticks mean, and leave with a clear next step. If the background is new to you, read our guide to who is owed money under the IEEPA tariff ruling first, then come back here.
How to use it: work through four parts. Parts A and B tell you whether you are the right party with the right duties. Part C tells you which filing route your entries fall into. Part D tells you what to fix before you file. Tap a box to tick it.
Transparency note: this guide is educational. At the end, we link to a referral partner and may earn a commission if you apply through that link. Read our affiliate disclosure and disclaimer.
In this guide
Gather these first
You will answer faster, and more accurately, with a few items open in front of you. None of them are hard to find, and your customs broker can supply most of them.
- A list of your entries from 2025 and early 2026, with entry numbers and dates.
- Your importer of record number and the exact legal name used on your entries.
- Broker statements or payment records showing the duties you paid.
- Liquidation dates for each entry, because they decide your route.
- Your ACE Portal login and bank details for refunds, if you already have them.
One record-keeping note: customs rules generally require importers to keep entry records for five years, so this paperwork should still exist. If it does not, ask your broker before assuming it is gone.
The 17-point eligibility checklist
Tick each statement that is true for your business. If you have several entry types, tick every box that applies in Part C.
Tip: if you are not sure about a box, leave it unticked and ask your broker. A blank box is useful information.
What your ticks mean
Match your pattern to the closest card below. These are general screening guides, not a determination of your rights.
Parts A and B ticked, plus unliquidated, recently liquidated or reconciliation-flagged entries in Part C
Likely worth filing nowYou appear to have entries that CAPE currently accepts. Close any gaps in Part D first, then file a CAPE Declaration, or ask the licensed broker who filed the entries to do it. Do not wait on entries liquidated recently, because the 80-day window keeps moving.
Parts A and B ticked, but your only Part C entries liquidated more than 80 days ago
Needs specialist adviceEntries that liquidated more than 80 days ago are outside standard CAPE Phase 1. CBP’s position has been that refunds on finally liquidated entries require a court case, and that question is on appeal. The Court of International Trade has signalled it will direct reliquidation for some of them. Speak with a trade attorney soon, because deadlines depend on your facts.
Only the open or suspended protest box ticked in Part C
Check with your brokerEntries with open or suspended protests are excluded from standard CAPE for now, and CBP has said it is building functionality for them. CBP has also said that if a protest was filed solely to get an IEEPA refund and the entry is within 80 days of liquidation, you may be able to withdraw it and use CAPE. Confirm the details before you act.
You could not tick Part A
You may not be the claimantRefunds go to the importer of record. If a supplier, marketplace or courier held that role, they are the party who can file, and any rights you have may depend on your contract. Ask them, and consider legal advice.
You could not tick Part B
Probably nothing to claimEntries with no IEEPA Chapter 99 line are not processed by CAPE. Ask your broker to confirm whether your entries ever carried those lines before you write them off.
Gaps in Part D
Fix these firstMissing ACE access or ACH enrollment is the most common reason refunds stall. CBP reported that about 20,000 refunds worth roughly $1.3 billion had not been sent as of September 11 because ACH details were missing. Start these steps now, because account approvals can take time.
Entries CAPE will not take
Even when you are the right party with the right duties, ACE removes certain entries during validation. CBP’s guidance lists these exclusions, and it is much better to know them before you upload a file.
- Entries past the 80-day window after liquidation.
- Entries with open or suspended protests.
- Entries tied to drawback or USMCA duty deferral programs.
- Antidumping or countervailing duty entries that are pending liquidation.
- Warehouse entries (types 21 and 22). These have been rejected since July 7, 2026, although warehouse withdrawals are still accepted.
- Entries where a surety paid the IEEPA duties. CBP advises leaving these out.
ACE removes ineligible entries and keeps processing the valid ones, so one problem entry does not necessarily sink an entire file. You can correct rejected entries and submit them separately.
How a “yes” turns into a rejection
Passing the checklist does not guarantee a clean filing. CBP’s figures as of September 11 show that roughly 201,000 of about 286,000 declarations passed file-level validation. The most common file-level problems it reported were:
At entry level, about 6.1 million entries failed validation, mainly because they were past CBP’s 90-day reliquidation authority, had no IEEPA Chapter 99 line, or had already appeared on an earlier declaration. Filings cannot easily be amended, so batch and review your list carefully before you upload it.
Your next 30 minutes
A checklist only helps if it leads to action. Here is a simple plan you can finish today.
- Finish the checklist. Tick every box that applies and note which cards above match you.
- Message your broker. Send the note below. It gets you the entry list, filing status and exclusions in one reply.
- Start ACE and ACH setup. If you lack an ACE Portal importer account or ACH refund enrollment, begin now. These steps often take the longest.
- Decide who will file. Choose between filing yourself, using your licensed broker, or getting professional help. Get fees and responsibilities in writing.
- Diary your dates. Note the liquidation dates of your newest entries, because the 80-day window is the most time-sensitive part.
Copy and send this to your broker
Hi [Name], I am checking our eligibility for IEEPA duty refunds. Could you please send me: (1) a list of all entries you filed for us with IEEPA Chapter 99 lines, with their liquidation dates; (2) confirmation of whether you have already filed a CAPE Declaration for any of them; and (3) whether any of those entries involve protests, drawback, USMCA duty deferral or a surety? Thank you.
How long each step takes
Timing varies, but this is the rough shape of the process from checklist to refund.
Refunds include interest and are paid by ACH to the bank account on file, and CBP nets out any balances you owe first. For a fuller explanation of the process, see our guide to how CAPE works.
Not a guarantee. This checklist screens your situation. It does not decide it. CBP validates every filing, and rules and court decisions in this area are still changing. Confirm your details with your broker or a qualified professional.
Frequently asked questions
Only the importer of record that paid the duties, or the licensed customs broker who filed the entries, can file a CAPE Declaration. If someone else was the importer of record, they are the party who files.
According to BDO's guidance, IEEPA tariffs paid from February 4, 2025 (fentanyl-related tariffs) and April 5, 2025 (reciprocal tariffs) through February 24, 2026 are eligible, along with certain other tariffs imposed under IEEPA.
CAPE Phase 1 accepts unliquidated entries and entries that liquidated within 80 days. Entries liquidated longer ago sit outside standard CAPE, and the path for finally liquidated entries is tied to court-ordered reliquidation that the government is contesting.
Refund rights follow the importer of record. If a supplier paid on delivered-duty-paid terms and was the importer of record, they hold the filing right. Whether you have any claim against them depends on your contract, so consider legal advice.
File the entries that qualify now and deal with the others separately. IORs and brokers can file multiple CAPE Declarations, each covering up to 9,999 entries.
Your customs broker can send you the list. If you have an ACE Portal account, you can also run ACE reports. Verify the numbers carefully, because wrong or nonexistent entry numbers are a common reason files fail.
Not for a basic screening like this one. Legal help matters most for finally liquidated entries, open protests and contract questions about who is entitled to the refund.
No. It is a screening tool. CBP validates each filing, and refund amounts, timing and eligibility depend on your individual circumstances.
Ticked the boxes? Or stuck on a few?
Whether your checklist looks strong or full of question marks, the quickest way to get clarity is to have your entries reviewed. Tariff Refund Agency describes its eligibility check as free, about five minutes long, and with no commitment.
Start Your Free Eligibility Check
Affiliate disclosure: if you apply through this button, we may earn a commission from Tariff Refund Agency. Refund eligibility, amounts and timing depend on individual circumstances and are never guaranteed. Read our affiliate disclosure and disclaimer.
Sources and further reading
- Tariff Refunds Finder: IEEPA Tariff Refund: Are You Owed Money by CBP?
- CBP: IEEPA Duty Refunds (official page)
- GHY International: CAPE progress and updates (updated September 16, 2026)
- BDO: IEEPA Tariff Refunds, Frequently Asked Questions
- Holland & Knight: IEEPA Tariff Refund Update, Government Appeals CIT Refund Order
Educational only. Tariff Refunds Finder is not CBP, U.S. Customs or a government agency, and this guide is not legal, tax or financial advice. Verify current details with CBP and a qualified professional before you act.
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