Who Is Eligible for the IEEPA Tariff Refund?

TL;DR – You're eligible if you were the Importer of Record, your entries fall between February 4, 2025 and early February 2026, they contain IEEPA HTS codes (9903.01.xx or 9903.02.xx), and they're either unliquidated or liquidated within the past 80 days. If your entries are older, a Form 19 protest may still work within 180 days of liquidation.

The Four Requirements

Eligibility for the IEEPA refund comes down to four conditions. You need all four:

1. You are the Importer of Record on the entries. The refund goes to whoever filed the entry with CBP and paid the duties – not the buyer of the goods. If a freight forwarder, FedEx Logistics, or DHL is listed as IOR on your CF-7501, the refund belongs to them. See Am I the Importer of Record? to verify.

2. Your entries fall within the IEEPA duty window. Only entries with an entry date from February 4, 2025 through early February 2026 are covered. Duties collected before or after that period were assessed under different authority and are not refundable through CAPE.

3. Your entries contain IEEPA HTS codes. The refundable codes are 9903.01.xx and 9903.02.xx. Section 301 (9903.88.xx), Section 232 (9903.80/81.xx), and Section 122 (9903.03.xx) are not refundable through CAPE. An entry that contains only Section 301 codes has nothing to refund. See IEEPA vs Section 301 for a full breakdown.

4. Your entries are within the eligible liquidation window. Unliquidated entries and entries liquidated within the past 80 days go through CAPE Phase 1. Entries liquidated 81–180 days ago require a Form 19 protest. Entries liquidated more than 180 days ago have no remaining path. See What Is Liquidation for how to determine which category your entries fall into.

Who Typically Qualifies

Direct importers with formal entries. If your company imported goods directly – you hired a customs broker, filed formal entries, and paid duties to CBP – you are almost certainly the IOR. Pull your ES-003 and check for 9903.01 or 9903.02 codes.

Small and mid-sized businesses that paid duties directly. The refund isn't limited by company size. CBP data shows 330,566 importers are affected, including a large share of small businesses that imported Chinese, Canadian, or Mexican goods during the IEEPA period.

FBA sellers who arranged their own customs clearance. If you used your own customs broker for inbound freight rather than Amazon's logistics service, you may be the IOR. Check your CF-7501 to confirm.

Who Typically Does Not Qualify

DDP importers. If your supplier shipped on DDP terms, their freight forwarder is typically the IOR – not you. You may have paid the duties indirectly through your invoice price, but CBP's refund goes to the IOR on record. See DDP Shipments and Courier as IOR.

Informal entries under the de minimis threshold. Shipments valued under $800 that entered as informal entries were not assessed formal duties and have nothing to refund.

Entries containing only Section 301 codes. Section 301 tariffs on Chinese goods (9903.88.xx) are not covered by CAPE. If your entries contain only Section 301 codes with no IEEPA codes alongside them, there is no CAPE refund.

Entries where the liquidation window has closed. If your entries were liquidated more than 180 days ago, both CAPE Phase 1 and Form 19 protest windows have passed. Those duties are no longer recoverable.

How to Check Your Entries

The fastest way to confirm eligibility is to pull your ES-003 report and look for IEEPA codes:

Pull your ES-003 from ACE Portal with Liquidation Status and Liquidation Date fields included. See How to Pull the ES-003 Report for exact steps.

Filter the HTS Code column for values starting with 9903.01 or 9903.02. Any rows that match represent IEEPA duties paid. Sum the Duty Amount column on those rows – that's your estimated refund before interest.

Check the Liquidation Status column on those same entries to confirm they fall within the eligible window.

If you have a mix of liquidated and unliquidated entries, CAPE Phase 1 handles both – you don't need to split them. Submit all eligible entries in one Declaration and CBP's secondary validation will sort them.

Frequently Asked Questions

I'm a small business – am I eligible? Yes, if you meet the four requirements above. Company size is not a factor. The refund goes to whoever was the Importer of Record and paid IEEPA duties during the eligible period. CBP data indicates the majority of the 330,566 affected importers are small and mid-sized businesses.

Do I need a customs broker to claim the refund? No. You can file a CAPE Declaration yourself through ACE Portal. You need an importer account, your ES-003 report, and a one-column CSV with your entry numbers. See How to File a CAPE Declaration. A broker can help if you have a large volume of entries or aren't comfortable with ACE Portal.

What if I imported through Amazon FBA? It depends on how your inbound freight was arranged. If you used Amazon Global Logistics (AGL) for inbound shipping, Amazon may be the IOR. If you arranged your own inbound freight with a separate customs broker, you may be the IOR. Check the IOR field on your CF-7501 for each shipment to confirm.

My goods are from China – am I eligible? Likely yes, at least partially. Chinese goods typically carry both Section 301 codes (9903.88.xx, not refundable) and IEEPA codes (9903.01.xx, refundable). Pull your ES-003 and filter for 9903.01 codes – those lines are refundable even if Section 301 lines on the same entry are not.