IEEPA Tariff Refund Calculator — Estimate Your Refund After SCOTUS Ruling

What Happened: SCOTUS Invalidated All IEEPA Tariffs

On February 20, 2026, the Supreme Court ruled 6–3 in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act does not grant the President authority to impose tariffs. The decision vacated every reciprocal tariff imposed under IEEPA since April 2025 — covering duties on imports from over 180 countries at rates ranging from 10% to 145%.

CBP confirmed that IEEPA duty collection ceased at 12:00 a.m. EST on February 24, 2026. On March 4, the Court of International Trade ordered CBP to begin processing refunds. The total refund pool is estimated at $175 billion or more in duties collected between April 2025 and February 2026.

How the IEEPA Refund Calculator Works

The IEEPA.co engine analyzes your import data at the HTS code level to determine exactly which duties were imposed under IEEPA authority versus other tariff programs (Section 301, Section 232, antidumping/countervailing duties). This distinction is critical because only IEEPA-specific duties are refundable.

What You Need

CBP Form 7501 data — entry date, declared value, country of origin
HTS classification codes — 8- or 10-digit codes from your entry summaries
Country of origin — determines which IEEPA executive order applies and the applicable rate

What You Get

IEEPA-specific duty amount — isolated from Section 301, 232, and AD/CVD duties
Applicable executive order — EO 14257 (baseline 10%), EO 14259 (China 145%), or EO 14266 (reciprocal rates)
Refund eligibility assessment — based on entry date, liquidation status, and protest deadlines
Protest deadline calculation — 180-day window under 19 U.S.C. § 1514

IEEPA Refund Timeline

Apr 2, 2025EO 14257 imposes baseline 10% IEEPA tariff on all imports. EO 14259 raises China rate to 145%. First IEEPA duties collected.

Apr 9, 2025EO 14266 imposes country-specific reciprocal rates ranging from 11% to 50%. Applies to 180+ countries.

Feb 20, 2026SCOTUS rules 6–3 in Learning Resources v. Trump that IEEPA does not authorize tariffs. All IEEPA duties vacated.

Feb 24, 2026CBP stops collecting IEEPA duties at 12:00 a.m. EST. New Section 122 10% global surcharge takes effect.

Mar 4, 2026Court of International Trade orders CBP to refund IEEPA duties. Importers begin filing claims.

Mar 12, 2026CBP files declaration with CIT detailing CAPE (Consolidated Administration and Processing of Entries) — a new ACE-based system for bulk IEEPA refund processing via CSV upload.

Who Is Eligible for IEEPA Tariff Refunds

Any importer of record who paid duties under IEEPA executive orders between April 2, 2025 and February 24, 2026 is potentially eligible. Refund eligibility depends on three factors:

Entry date — must fall within the IEEPA collection period
Liquidation status — unliquidated entries can be corrected via Post-Summary Correction (PSC) in ACE; liquidated entries require a formal protest under 19 U.S.C. § 1514
Protest deadline — 180 days from date of liquidation. Missing this window forfeits the refund.

Customs brokers can file on behalf of importers. The registered importer of record may also designate an attorney or licensed broker to act as their agent for refund claims.

IEEPA vs. Other Tariff Programs: Why It Matters

Not all duties collected during 2025–2026 are refundable. The SCOTUS ruling only applies to tariffs imposed under IEEPA authority. Other trade remedy duties remain in effect:

Section 301 (China) — 25% on Lists 1–4A. Not refundable under this ruling.
Section 232 (Steel/Aluminum) — 25% on steel, 10% on aluminum. Not refundable.
AD/CVD orders — Product-specific antidumping and countervailing duties. Not refundable.
IEEPA reciprocal tariffs (HTS 9903.01) — Fully refundable.
IEEPA China-specific tariffs (HTS 9903.01.25) — The IEEPA portion above baseline rates is refundable.

Many importers have entries with stacked duties — IEEPA tariffs layered on top of Section 301 or 232 duties. The ieepa.co calculator isolates the IEEPA-specific component so you know exactly what is recoverable.

How to File Your IEEPA Refund Claim

Path 1: CAPE Bulk Processing (New — March 2026)

CBP is building a new system called CAPE (Consolidated Administration and Processing of Entries) within the ACE platform specifically to handle mass IEEPA refund claims. CAPE allows importers and brokers to upload CSV files listing affected entry summaries. The system automatically validates submissions, removes IEEPA Chapter 99 HTS numbers from entries, recalculates duties, and processes refunds electronically.

CAPE Process

Step 1: Upload CSV of affected entry summaries through the CAPE Claim Portal in ACE
Step 2: System validates file formatting, broker authorization, and IEEPA Chapter 99 HTS numbers
Step 3: CAPE removes IEEPA tariff classifications and recalculates duties with interest
Step 4: Entries are scheduled for liquidation/reliquidation and refunds issued via ACH or CBP Form 4811

Status (March 2026): CAPE is under active development with component completion ranging from 40% to 80%. CBP plans a phased rollout, initially addressing straightforward claims. The CIT has paused the requirement for immediate refunds pending system readiness. Importers should prepare their entry data now.

Path 2: Post-Summary Correction (PSC) for Unliquidated Entries

Use the Post-Summary Correction (PSC) process through CBP's Automated Commercial Environment (ACE). File electronically via ES-003 to correct the entry summary data and remove IEEPA duty amounts. This is the fastest path to recovery.

Path 3: Formal Protest for Liquidated Entries

File a formal protest under 19 U.S.C. § 1514 within 180 days of the liquidation date. Reference the SCOTUS decision in Learning Resources, Inc. v. Trump as the legal basis. CBP is required to process these protests given the court order.

Path 4: Update Existing Protests

If you previously protested IEEPA duties, the CIT order strengthens your position. Contact your customs broker or attorney to update the protest with the SCOTUS ruling citation.

Frequently Asked Questions

How much can I get back in IEEPA refunds?

Your refund equals the total IEEPA-specific duties paid on entries between April 2, 2025 and February 24, 2026. Use the ieepa.co calculator to estimate your exposure by entering your HTS codes, entry dates, and country of origin.

What is the deadline to file for an IEEPA refund?

For liquidated entries, you have 180 days from the date of liquidation to file a protest under 19 U.S.C. § 1514. For unliquidated entries, file a PSC through ACE as soon as possible. There is no fixed deadline for unliquidated entries, but acting quickly is advisable as entries liquidate on a rolling basis.

Are Section 301 tariffs on China also refundable?

No. The SCOTUS ruling only applies to tariffs imposed under IEEPA authority. Section 301 tariffs (25% on Lists 1–4A) were imposed under a different statute and remain in effect. However, if your Chinese imports had both Section 301 and IEEPA duties stacked, the IEEPA portion is refundable.

Can my customs broker file the refund claim for me?

Yes. Licensed customs brokers can file PSC corrections and formal protests on behalf of importers of record. Many brokers are already processing bulk refund claims for their clients.

What is an ACE ES-003 correction?

ES-003 is the electronic entry summary correction type in CBP's Automated Commercial Environment (ACE). It allows importers or their brokers to modify entry summary data — including duty amounts — on unliquidated entries. This is the primary mechanism for recovering IEEPA duties on entries that have not yet been liquidated.

How long will it take to receive my IEEPA refund?

Processing times vary. PSC corrections on unliquidated entries are typically faster than formal protests. The Treasury Department processes refunds electronically via ACH. CBP has indicated it will prioritize IEEPA refund processing given the CIT order, but the volume of claims is unprecedented.

What is CBP's CAPE system for IEEPA refunds?

CAPE (Consolidated Administration and Processing of Entries) is a new platform within CBP's Automated Commercial Environment (ACE) designed specifically for processing bulk IEEPA refund claims. Importers and brokers upload CSV files listing affected entries; the system automatically strips IEEPA Chapter 99 HTS numbers, recalculates duties, and issues refunds electronically. As of March 2026, CAPE is under active development with a phased rollout planned.

Start Your IEEPA Refund Analysis

The IEEPA.co duty impact engine runs calculations entirely client-side — no financial data leaves your browser. Enter your HTS codes and entry data to get an instant estimate of your recoverable IEEPA duties.

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