If you have paid tariffs on imported goods in the past year, there is a strong chance you are owed money back. The Supreme Court’s February 2026 ruling striking down IEEPA tariffs means an estimated $175–$179 billion in tariff payments are now refundable — and the CBP system to claim those refunds went live today, April 20, 2026. Separately, the long-standing duty drawback program allows importers to recover up to 99% of duties paid on goods that are re-exported or destroyed. This guide walks you through both programs, how to access them on the CBP website, and exactly what you need to file your claim.
In This Guide
- Two Paths to a Tariff Refund: IEEPA vs Duty Drawback
- IEEPA Tariff Refunds: What Happened and Who Qualifies
- The CAPE System: How to File Your IEEPA Refund
- Accessing the CBP ACE Portal: Step-by-Step
- Traditional Duty Drawback: Types and Eligibility
- How to File a Duty Drawback Claim
- Required Documents for Both Programs
- Refund Timelines: When to Expect Your Money
- Section 301 and Section 232: What Is Eligible?
- How Your 3PL Partner Can Help
- Frequently Asked Questions
Two Paths to a Tariff Refund: IEEPA vs Duty Drawback
Before diving into procedures, it is critical to understand that there are two entirely separate mechanisms for recovering tariff payments from U.S. Customs and Border Protection:
IEEPA Tariff Refunds (New — 2026)
Refunds of tariffs that were imposed under the International Emergency Economic Powers Act and subsequently declared unconstitutional by the Supreme Court in February 2026. These cover reciprocal tariffs, fentanyl tariffs on China/Canada/Mexico, and India IEEPA tariffs. Filed through the new CAPE system in the ACE Portal. Available to ALL importers who paid these tariffs.
Duty Drawback (Established Program)
Recovery of up to 99% of duties, taxes, and fees on imported goods that are subsequently exported, used in manufacturing for export, or destroyed. Governed by 19 U.S.C. Section 1313. Filed electronically through the Automated Broker Interface (ABI). Available to importers who re-export or destroy goods.
IEEPA Tariff Refunds: What Happened and Who Qualifies
On February 20, 2026, the Supreme Court ruled 6–3 in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. The decision invalidated all tariffs imposed under IEEPA since their inception, including:
- Reciprocal tariffs — 10% or higher on most countries (effective April 2025)
- Fentanyl tariffs — 10% on China, 35% on certain Canadian goods, 25% on certain Mexican goods
- India IEEPA tariffs — 25% additional duties (August 6 – February 7, 2026)
The ruling was retroactive. Every dollar paid under these tariffs since their inception is potentially refundable. The Penn-Wharton Budget Model estimates the total refundable amount at $175–$179 billion across all affected importers.
Who Qualifies for IEEPA Refunds?
You qualify if you:
- Imported goods into the United States during the period IEEPA tariffs were in effect
- Paid duties specifically attributed to IEEPA tariff layers (Chapter 99 HTS headings)
- Have an ACE Portal account or can establish one
- Have ACH (electronic bank) information registered with CBP for refunds
This applies to businesses of all sizes — from major multinational importers to small businesses that imported a single container. If you paid IEEPA tariffs, you are owed a refund.
The CAPE System: How to File Your IEEPA Refund
CAPE (Consolidated Administration and Processing of Entries) is the new ACE Portal functionality built specifically for IEEPA refund processing. Phase 1 launched April 20, 2026 at 8:00 AM EST — today.
CAPE Phase 1: What Is Covered
Phase 1 covers the following entry types:
- Unliquidated entries (duties paid but entry not yet finalized)
- Entries within 80 days of liquidation
- Suspended or extended entries
- Entries under CBP review
- Certain warehouse entries
CAPE Phase 1: What Is Excluded
- Entries liquidated more than 80 days ago (covered in future phases)
- Reconciliation entries
- Entries already covered by drawback claims
- Entries under active protest
- Certain AD/CVD (antidumping/countervailing duty) cases
- Entries not originally filed in ACE
How to File a CAPE Declaration: Step-by-Step
Verify Your ACE Portal Account
Log into the ACE Portal at trade.cbp.dhs.gov. If you do not have an account, register immediately at the ACE Portal public dashboard. Your customs broker may file on your behalf if they have Power of Attorney on file.
Confirm ACH Refund Registration
As of February 6, 2026, CBP issues ALL refunds electronically via ACH. No paper checks. Navigate to your ACE account settings and verify that your bank ACH information is registered specifically for refunds (this is separate from your payment ACH). If ACH info is not on file, CBP will hold your refund indefinitely until you register.
Gather Your Entry Numbers
Compile a list of all entry numbers where you paid IEEPA tariffs. Each entry number is 11 alphanumeric characters. Request an IEEPA-duty-only entry report from your customs broker showing duties broken out by tariff layer (you need to isolate the IEEPA component from other duties on the same entry).
Prepare Your CSV File
CAPE requires a CSV upload file containing your entry numbers. Each CAPE Declaration can include up to 9,999 entries. If you have more entries, you can file multiple declarations. Follow CBP’s CSV template format exactly — available on the IEEPA Duty Refunds page at cbp.gov.
Submit Your CAPE Declaration
In the ACE Portal, navigate to the CAPE module. Upload your CSV file and review the declaration summary. Critical warning: No amendments are permitted after a CAPE Declaration is accepted. Double-check all entry numbers before submitting. Once accepted, expect your refund within 60–90 days via ACH.
Accessing the CBP ACE Portal: Step-by-Step
The Automated Commercial Environment (ACE) is CBP’s online trade processing system. It is the gateway to both IEEPA refunds and drawback claim management.
How to Access ACE
- URL: https://trade.cbp.dhs.gov/ace/dashboard/public/
- Registration: New users go to cbp.gov/trade/automated/how-to-use-ace
- IEEPA Refund Page: cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
- Drawback Overview: cbp.gov/trade/programs-administration/entry-summary/drawback-overview
Key CBP Resources
| Resource | URL |
|---|---|
| ACE Portal (Login) | trade.cbp.dhs.gov |
| IEEPA Duty Refunds (CAPE) | cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds |
| Drawback Overview | cbp.gov/trade/programs-administration/entry-summary/drawback-overview |
| Drawback FAQs | cbp.gov/trade/automated/news/drawback/drawback-ace-frequently-asked-questions-faqs |
| ACH Refund Setup | cbp.gov/trade/automated/ach/refund |
| How to File Drawback | help.cbp.gov/s/article/Article-1152 |
Traditional Duty Drawback: Types and Eligibility
Duty drawback is an established CBP program authorized under 19 U.S.C. Section 1313 that allows companies to recover up to 99% of duties, taxes, and certain fees on imported merchandise when those goods are exported, used in manufacturing for export, or destroyed. Unlike IEEPA refunds, duty drawback is an ongoing program available to qualifying importers at any time.
Types of Duty Drawback
Manufacturing Drawback
Section 1313(a) & (b). Applies when imported materials are used to manufacture products that are exported. Two methods: Direct Identification (track actual imported goods through manufacturing) or Substitution (use domestic goods classifiable under the same 8-digit HTSUS code). Substitution is the more common method as it provides flexibility.
Unused Merchandise Drawback
Section 1313(j). Covers imported goods that are exported or destroyed without being used in the United States. Ideal for distributors who re-export inventory, redirect products to international markets, or return unsold goods. Also supports substitution on the same 8-digit HTS classification.
Rejected Merchandise Drawback
Section 1313(c). For goods that are defective, do not meet specifications, were shipped without consent, or were returned from retail. Unique in that it does not require export — focused on proving goods were unusable or not delivered as expected. Goods must be removed from commerce under CBP supervision.
Destruction Drawback
Under Section 1313. Allows duty recovery on imported merchandise destroyed under CBP supervision. Covers goods that are obsolete, damaged, or unsuitable for U.S. sale. Useful for expired perishables, defective products, or goods damaged in transit that cannot be sold domestically.
Key Drawback Rules
- Export or destruction must occur within 5 years of the original import date
- Claims must be filed within 5 years of importation
- Recovery is up to 99% of duties paid (1% retained by CBP)
- Paper claims have NOT been accepted since February 2019 — all filings are electronic
- Substitution requires matching on the same 8-digit HTSUS subheading
- Cannot substitute based on HTS number if the article description begins with “other”
How to File a Duty Drawback Claim
Determine Eligibility
Confirm you import goods into the U.S. and pay duties. Confirm those goods (or products made from them) are exported, destroyed, or rejected. Identify which drawback type applies: manufacturing, unused merchandise, rejected, or destruction.
Register with CBP and Obtain Privileges
Obtain an ACE Portal account. Apply for Accelerated Payment (AP) Privilege — this speeds refunds to approximately 3 weeks instead of 6–12 months. Also apply for Waiver of Prior Notice (WPN) to file without advance notice of export/destruction. Both privileges require an active and sufficient 1A bond filed electronically in E-Bonds. Approval takes up to 90 days, so apply early.
Match Import and Export Records
Use either Direct Identification or Substitution method to match your imports to your exports. For Direct Identification, maintain a clear chain of custody from import to export. For Substitution, verify that both the imported and substituted goods share the same 8-digit HTSUS classification. Maintain detailed inventory records throughout.
Choose a Filing Method
All drawback claims must be filed electronically via ABI (Automated Broker Interface). Three options: (1) Self-file using ABI-compatible software and your own communications link with CBP, (2) Engage a licensed customs broker, or (3) Use a dedicated drawback service provider. Most small and mid-size importers use a broker or specialist.
File and Await Refund
Submit CBP Form 7553 (Notice of Intent to Export/Destroy) along with supporting documentation. With Accelerated Payment approval, refund arrives within approximately 3 weeks of claim acceptance. Without AP, expect 6–12+ months. Maintain all records for 3 years after claim liquidation.
Required Documents for Both Programs
For IEEPA Refunds (CAPE System)
- Active ACE Portal account
- ACH bank information registered in ACE (refund-specific, not just payment)
- CSV file with entry numbers (11 alphanumeric characters each)
- IEEPA-duty-only entry report from your broker (duty broken out by tariff layer)
- Entry summaries (CBP Form 7501) for verification
For Traditional Duty Drawback
- CBP Form 7501 (Entry Summary) — proof of duties paid
- CBP Form 7553 (Notice of Intent to Export/Destroy)
- Commercial invoices (both import and export)
- Import purchase orders and export sales orders
- Bill of lading / export waybills (proof of export)
- Bill of materials or formula (for manufacturing drawback, identifying merchandise by 8-digit HTS and quantity)
- Foreign entry copies
- Inventory records with clear chain of custody
- Warehouse receipts
- HTSUS classification codes (especially Chapter 99 tariff lines)
- Manufacturing/production records (for manufacturing drawback)
Refund Timelines: When to Expect Your Money
| Program | Milestone | Timeframe |
|---|---|---|
| IEEPA / CAPE | Refund after declaration accepted | 60–90 days |
| Drawback (with AP) | Refund after claim accepted | ~3 weeks |
| Drawback (no AP) | Refund after full liquidation | 6–12+ months |
| Drawback | Filing deadline from import date | 5 years |
| Drawback | AP/WPN privilege application review | Up to 90 days |
| Both | Record retention after liquidation | 3 years |
Section 301 and Section 232: What Is Eligible?
Not all tariffs are treated equally for refund and drawback purposes. Here is the current landscape:
Section 301 Tariffs (Chinese Imports) — DRAWBACK ELIGIBLE
Section 301 duties on Chinese imports are fully eligible for duty drawback. These tariffs range from 10% to 25% across three lists of goods. If you import goods subject to Section 301 tariffs and subsequently export those goods (or substitutable goods under the same 8-digit HTS), you can recover up to 99% of the Section 301 duties paid.
- Can file under TFTEA rules with a 5-year lookback from the import date
- Three lists of affected goods with tariffs of 10%, 25%, or cumulative rates
- New Section 301 investigations targeting ~100 countries expected summer 2026
Section 232 Tariffs (Steel, Aluminum, Copper) — MOSTLY NOT ELIGIBLE
Section 232 tariffs are generally NOT eligible for duty drawback per Presidential Proclamations 9739 and 9740. This includes:
- 25% tariffs on steel and aluminum
- 50% on certain steel/aluminum/copper articles
- Up to 100% on certain pharmaceutical products
Exception: Drawback IS available for Section 232 tariffs on automobiles and automobile parts.
Section 122 Bridge Tariffs — Under Legal Challenge
Following the IEEPA ruling, the administration imposed 15% across-the-board tariffs under Section 122 of the Trade Act of 1974 as a temporary bridge (authorized for 150 days only, effective February 7, 2026). These face their own legal challenges and may also be refundable depending on court outcomes.
Need Help Navigating Tariff Refunds?
Miami Alliance 3PL maintains detailed receiving, storage, and export records that support your drawback claims. Our team coordinates with customs brokers to ensure your documentation is complete. Get started with a free consultation.
Get an Instant QuoteHow Your 3PL Partner Can Help with Tariff Refunds
Your warehouse and logistics partner plays a critical role in enabling tariff refund claims. Here is how a well-equipped 3PL supports the process:
Detailed Receiving Documentation
Every inbound shipment at a professional 3PL is documented with date, quantity, SKU, condition, and origin information. These receiving records establish the import-to-warehouse chain of custody that CBP requires for drawback claims.
Inventory Tracking & Snapshots
WMS (Warehouse Management System) data provides timestamped inventory positions that prove goods were held, stored, and subsequently exported or transferred. Daily storage snapshots serve as evidence of custody throughout the drawback timeline.
Export & Outbound Records
When goods leave the warehouse for export, your 3PL generates pick/pack records, outbound BOLs, and shipping documentation. These documents prove the export occurred and link back to specific imported inventory — the core requirement of duty drawback.
Customs Broker Coordination
A 3PL embedded in international trade (like one operating near PortMiami) works alongside customs brokers daily. They can facilitate the information flow between your broker, your import records, and CBP — reducing the administrative burden of assembling a drawback claim.
Foreign Trade Zone Access
Some 3PLs operate within or adjacent to Foreign Trade Zones, allowing you to defer, reduce, or eliminate duties entirely on goods stored for re-export. FTZ operations create additional pathways to minimize your tariff exposure beyond traditional drawback.
Document Retention & Compliance
CBP requires 3 years of record retention after claim liquidation. A professional 3PL maintains digital records of all transactions, ensuring your documentation is available if CBP audits your drawback claim years after the fact.
Frequently Asked Questions
How do I claim a tariff refund from CBP?
There are two paths. For IEEPA tariffs (struck down February 2026), use the new CAPE system in the ACE Portal at trade.cbp.dhs.gov — file a consolidated declaration with your entry numbers via CSV upload. For duty drawback (goods that were re-exported or destroyed), file electronically through ABI using a licensed customs broker or drawback specialist. Both require an ACE Portal account and ACH bank information on file.
What is the CAPE system for IEEPA refunds?
CAPE (Consolidated Administration and Processing of Entries) is CBP’s new system launched April 20, 2026 specifically for processing IEEPA tariff refunds. It allows importers to file consolidated refund declarations through the ACE Portal by uploading a CSV file with entry numbers. Phase 1 covers unliquidated entries and entries within 80 days of liquidation. Refunds are processed within 60–90 days of declaration acceptance.
How long does it take to receive a tariff refund?
IEEPA refunds through CAPE take approximately 60–90 days after your declaration is accepted. Traditional duty drawback with Accelerated Payment privilege takes about 3 weeks after acceptance. Without Accelerated Payment, standard drawback claims can take 6–12 months or longer.
Are Section 301 tariffs eligible for duty drawback?
Yes. Section 301 duties on Chinese imports are fully eligible for duty drawback. If you import goods subject to Section 301 tariffs and subsequently export those goods (or substitutable goods under the same 8-digit HTSUS), you can recover up to 99% of the duties paid. You can file under TFTEA rules with a 5-year lookback from the import date.
Do I need a customs broker to file for a tariff refund?
For IEEPA refunds via CAPE, you can file directly through your ACE Portal account without a broker. For traditional duty drawback claims, you technically can self-file by purchasing ABI-compatible software, but most companies use a licensed customs broker or drawback specialist because the documentation and compliance requirements are complex. A 3PL partner with customs expertise can coordinate the process.