Last reviewed: October 5, 2026. Reading time: about 9 minutes.
No, in most cases you are not getting back everything you paid. This surprises a lot of importers, and it is the single most common source of inflated refund expectations we see. The IEEPA refund program covers exactly one layer of duty, the one imposed under the International Emergency Economic Powers Act. If your entries also carried Section 301, Section 232, or standard MFN duties, as many entries from China and several other countries did, those layers stay in place.
This guide explains why duties stack, which layer is actually refundable, and how to find the exact number on your own entries so you are working from reality instead of your total duties paid line.
The short version: only duties assessed under IEEPA, the fentanyl-related tariffs, the reciprocal tariffs, and related country-specific emergency tariffs imposed between roughly February 2025 and February 24, 2026, are refundable through CAPE. Section 301, Section 232, Section 122, antidumping and countervailing duties, and standard MFN duties are separate legal authorities and are not part of this refund.
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
Why duties stack in the first place
A single imported product can be subject to several different duty authorities at once, each created by a different law or executive action, each with its own purpose, and each tracked separately by CBP. A shipment of Chinese-origin electronics in 2025, for example, could have carried a standard MFN base rate, an existing Section 301 tariff tied to earlier trade actions, and a new IEEPA-based surcharge, all stacked on top of each other on the same entry.
The Supreme Court’s February 2026 ruling addressed only the legal basis for IEEPA tariffs specifically. It did not touch the other authorities, which remain separately enacted and, in most cases, still in effect today.
Which authorities are refundable, and which are not
IEEPA tariffs — The fentanyl-related tariffs, reciprocal tariffs, and related country-specific emergency tariffs imposed roughly February 2025 through February 24, 2026. This is the only authority covered by the Supreme Court ruling and the only one refundable through CAPE.
Section 301 tariffs — China-specific tariffs tied to earlier trade investigations, largely unaffected and, in some cases, expanding. Not part of the IEEPA ruling.
Section 232 tariffs — Tariffs on steel, aluminum and certain derivative products, imposed under a separate national security authority. Not part of the IEEPA ruling.
Section 122 surcharge — A temporary, lower-rate surcharge under its own authority, since expired. It has no bearing on your IEEPA refund either way.
Antidumping and countervailing duties — Assessed under their own separate legal process, unrelated to IEEPA.
Standard MFN (Column 1) duty — The ordinary base tariff rate that applies to most imports regardless of any emergency tariff action. Not refundable under this program.
A worked example
This is a hypothetical illustration to show how the math separates, not a real case or an average.
Illustrative example: one entry, three duty layers
In this illustration, the business paid $7,200 in total duties, but only the $2,400 IEEPA portion is eligible for a CAPE refund, about a third of what was paid, not the full amount. This is exactly the kind of gap that surprises importers who estimated their refund from their total duty line instead of isolating the IEEPA-specific charge.
How to find your actual IEEPA amount
- Pull your entry summary (CBP Form 7501). Your customs broker can provide this for any entry, or you can review it yourself if you have ACE Portal access.
- Look specifically for HTS Chapter 99 lines. IEEPA duties are coded under their own Chapter 99 provisions, separate from the Chapters 1 through 97 lines used for Section 301 and Section 232 duties.
- Do not use your total duties paid figure. This number typically combines every authority stacked on the entry, not just the refundable portion.
- Ask your broker to isolate the IEEPA line specifically. If you are unsure which lines are which, this is a quick, specific question for your broker rather than something to estimate yourself.
- Use that isolated figure for your own refund estimate. Our amount guide covers how interest is added to this figure once you have it.
The filing mistake this causes
A CAPE Declaration that includes total duties paid, or any Section 301 or Section 232 amounts, will be rejected for that entry. CBP's system is built to recalculate the IEEPA-specific line only. Submitting a broader figure, even by accident, does not get you a larger refund; it gets the entry kicked back. This is one more reason the screening discipline covered in our mistakes guide matters so much before you file.
What about your other duties?
If your Section 301 or Section 232 duties were significant, it is natural to wonder whether there is any way to recover those separately. There generally is not through this program, but two things are worth knowing:
- Section 301 exclusions are a separate, unrelated process some importers used in past years. They do not affect, and are not affected by, your IEEPA refund eligibility.
- Duty drawback is a different, ongoing federal program that can, in some cases, recover duties from multiple authorities, including Section 301, Section 232 and even IEEPA, but only when the imported goods were later exported or used to manufacture an exported product. It is a separate process with its own conditions, outside the scope of CAPE and outside what this site covers in detail.
Frequently asked questions
Generally no, unless IEEPA was the only duty authority that applied to your entries. For most importers, the refund covers only the IEEPA-specific portion, which is often a fraction of total duties paid.
Check your entry summaries for HTS Chapter 99 lines, which carry IEEPA duties separately from the Chapters 1 through 97 lines used for Section 301, Section 232 and MFN duties. Your customs broker can isolate this for you.
Not through this program. Section 301 remains a separate, active authority, and the Supreme Court's ruling addressed only IEEPA's legal basis, not Section 301's.
Ask your broker for a duty authority breakdown on your entries. Not every importer had overlapping duties; some entries carried IEEPA duties alone.
Duty drawback is a separate, ongoing program that can sometimes recover these, but only when goods were exported or used in an exported product. It has its own process, outside of CAPE.
Yes. Our guide to how much you could get back is built around your actual IEEPA duties paid specifically, not your total duty line, which is exactly the distinction this article explains in more depth.
Find your actual IEEPA-specific amount
Even if it is only part of what you paid, the IEEPA portion alone can still be significant. Tariff Refund Agency offers a free eligibility check that takes about five minutes, 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?
- Tariff Refunds Finder: How Much Could Your Business Get Back in IEEPA Tariff Refunds?
- Tariff Refunds Finder: 5 Costly Mistakes That Can Delay Your CAPE Refund Claim
- Tariff Refunds Finder: Tariff Refund Eligibility Checklist for US Importers (2026)
- CBP: IEEPA Duty Refunds (official page)
- BDO: IEEPA Tariff Refunds, Frequently Asked Questions
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. Confirm the duty authority breakdown on your own entries with your customs broker before estimating a refund.
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