U.S. Tariffs Refund 2026: Everything Importer Need To Know (IEEPA Refund)

Key Takeaways

• Supreme Court invalidated IEEPA tariffs on February 20, 2026 (6-3 ruling). Approximately $166 billion in duties collected from 330,000+ importers across 53 million shipments (April 2025 - February 2026) is now refundable.
• CAPE portal is live as of April 20, 2026. Filed exclusively through the ACE Secure Data Portal; only the Importer of Record or licensed customs broker can submit. Refunds expected within 60-90 days of declaration acceptance.
• Phase 1 covers ~82% of IEEPA duties ($127B including interest) — limited to unliquidated entries and entries within 80 days of liquidation. As of April 14, 56,497 importers had completed ACH registration.
• Only IEEPA tariffs qualify. Section 232 (metals, autos, pharma), Section 301 (China), Section 122 (10% surcharge), and anti-dumping/countervailing duties remain in force and are not refundable.
• Highest-exposure sectors (per yTrade customs data): industrial machinery HS 84 ($463B+ in top 5 codes), electronics HS 85 ($376B+), non-Section 232 automotive components HS 87, and apparel HS 61-62 ($82.12B combined).
• Vietnam carries the largest per-entry refund potential (IEEPA rates up to 46%). Mexico and Canada entries frequently claimed USMCA exemptions, shrinking their refund pool despite high trade volumes.

On February 20, 2026, the U.S. Supreme Court ruled 6-3 that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to impose tariffs. That ruling invalidated the tariff regime that had been applied to imports from virtually every trading partner since April 2025, and opened a refund path for importers who paid duties under that specific authority.

According to CBS News, the government could owe businesses up to $175 billion in refunds following the landmark decision, where approximately $166 billion in IEEPA duties were collected from more than 330,000 importers across 53 million shipments between April 2025 and February 2026.

On April 20, 2026, CBP launched the first phase of its electronic refund system, the Consolidated Administration and Processing of Entries (CAPE), through the ACE Secure Data Portal. The CAPE tool is the exclusive mechanism for requesting refunds of IEEPA duties. This is not a universal tariff refund. It applies only to duties collected under IEEPA authority, not to Section 232 (steel, aluminum, copper, autos, pharmaceuticals), Section 301 (China), Section 122 (the 10% global surcharge), or anti-dumping and countervailing duties.

U.S. Tariffs Refund: What Are Eligible Industries?

The single most critical distinction for importers is that only IEEPA-imposed tariffs qualify for this refund process.

In fact, the CAPE system is designed exclusively for refunds of duties imposed under IEEPA authority that were subsequently invalidated by the courts. Section 232 tariffs on metals, autos, and pharmaceuticals, Section 301 tariffs on Chinese goods, the Section 122 global surcharge, and anti-dumping or countervailing duties are all governed by separate legal authorities and are not part of this refund process.

Tariffs Covered By The IEEPA Refund Process

• "Reciprocal" and "baseline" tariffs imposed under IEEPA authority beginning April 2025.
• Both the "Trafficking" tariffs on Canada, Mexico, and China (fentanyl-related) and the "Reciprocal" tariffs imposed globally on April 2, 2025.
• Duties collected under these tariff lines are now eligible for refund through the CBP CAPE portal.

Tariffs That Are NOT Part Of This Refund Process

Tariff Authority	Status As Of April 2026	Refundable?
IEEPA reciprocal/baseline tariffs	Struck down by Supreme Court (Feb 20, 2026)	Yes
Section 232 (steel, aluminum, copper)	In force, restructured April 6, 2026 (25-50%)	No
Section 232 (autos and auto parts)	In force at 25%	No
Section 232 (pharmaceuticals)	Effective July-September 2026 (up to 100%)	No
Section 301 (China)	In force with exclusion extensions	No
Section 122 (10% global surcharge)	In force since Feb 24, 2026 (150-day duration)	No
Anti-dumping / countervailing duties	Case-by-case, ongoing	No

As Plante Moran noted in April 2026, importers must carefully distinguish the IEEPA refund process from continuing Section 232 pressure. The two regimes operate under entirely separate legal authorities.

Which Sectors Have The Highest IEEPA Tariff Exposure

While refund eligibility is entry-based rather than industry-based, certain import sectors had significantly higher IEEPA exposure based on trade volume.

The industries most exposed to IEEPA-based tariffs include industrial manufacturing, consumer electronics, automotive components, and retail goods, Reuters reported, reflecting the breadth of country coverage under the original tariff regime.

Meanwhile, retailers, industrial manufacturers, and technology companies are expected to be among the first to receive refunds given their high entry volumes.

Industrial Products And Manufacturing

U.S. industrial machinery imports (HS 84) represent one of the highest-exposure categories for IEEPA refunds. According to yTrade customs data, the top 5 HS codes within this chapter generated a combined import value exceeding $463 billion in 2025, with data processing machines (HS 8471) alone accounting for $281.7 billion, or 36.38% of the chapter. Multi-country sourcing of industrial inputs from IEEPA-affected origins means many of these entries carried IEEPA baseline rates rather than Section 232 metals tariffs.

• HS 8471 (data processing machines, optical readers): $281.7 billion (36.38%), the single largest industrial import category by value
• HS 8473 (machinery parts and accessories): $101.0 billion (13.05%), broad sourcing from IEEPA-affected Asian and European origins
• HS 8411 (turbo-jets, turbo-propellers, gas turbines): $33.1 billion (4.27%), specialized aerospace and energy components
• HS 8481 (taps, cocks, valves for pipes): $24.7 billion (3.19%), industrial plumbing and process equipment
• HS 8414 (air pumps, compressors, fans): $22.4 billion (2.90%), HVAC and manufacturing support equipment

HS Code	Description	Value (US$)	%	Quantity	%
8471	Automatic data processing machines and units thereof, magnetic or optical readers, machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included	281.7B	36.38%	575.6M	2.04%
8473	Machinery; parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 84.70 to 84.72	101.0B	13.05%	904.2M	3.20%
8411	Turbo-jets, turbo-propellers and other gas turbines	33.1B	4.27%	99.2M	0.35%
8481	Taps, cocks, valves and similar appliances for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves	24.7B	3.19%	2.7B	9.72%
8414	Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan; gas-tight biological safety cabinets whether or not fitted with filters	22.4B	2.90%	885.7M	3.13%

Industrial importers should verify whether their HS 84 entries were classified under IEEPA tariff lines versus Section 232 (for metal-heavy components).

Explore how yTrade maps HS code exposure across 200+ countries.

Technology And Electronics

U.S. electronics imports (HS 85) carry significant IEEPA exposure, with the top 5 categories generating over $376 billion in 2025 import value, from yTrade customs data.

Telephone sets and smartphones (HS 8517) led at $192.6 billion (28.90%), followed by electric accumulators (HS 8507) at $52.2 billion. The critical caveat for this sector: Chinese-origin goods may overlap with Section 301 tariffs, meaning only the IEEPA portion of duties paid on Chinese imports would qualify for refund.

• HS 8517 (telephones, smartphones, network equipment): $192.6 billion (28.90%), the largest electronics import category by value
• HS 8507 (electric accumulators, batteries): $52.2 billion (7.83%), driven by EV battery and consumer electronics demand
• HS 8542 (electronic integrated circuits): $45.0 billion (6.76%), semiconductors and chips from multiple IEEPA-affected origins
• HS 8544 (insulated wire, cable, fibre optics): $44.3 billion (6.65%), infrastructure and data connectivity components
• HS 8504 (transformers, static converters): $42.1 billion (6.32%), power management and grid equipment

HS Code	Description	Value (US$)	%	Quantity	%
8517	Telephone sets, including smartphones and other telephones for cellular/wireless networks; other apparatus for the transmission or reception of voice, images or other data (including wired/wireless networks), excluding items of 8443, 8525, 8527, or 8528	192.6B	28.90%	1.2B	0.31%
8507	Electric accumulators, including separators therefor; whether or not rectangular (including square)	52.2B	7.83%	1.2B	0.32%
8542	Electronic integrated circuits	45.0B	6.76%	13.0B	3.47%
8544	Insulated wire, cable and other electric conductors, connector fitted or not; optical fibre cables of individually sheathed fibres, whether or not assembled with electric conductors or fitted with connectors	44.3B	6.65%	26.6B	7.10%
8504	Electric transformers, static converters (e.g. rectifiers) and inductors	42.1B	6.32%	8.6B	2.29%

Automotive (Non-Section 232 Components)

U.S. automotive imports (HS 87) present a nuanced refund picture.

According to Automotive News, finished vehicles and many auto parts remain subject to Section 232 tariffs at 25% and are not eligible for IEEPA refunds.

However, certain non-Section 232 automotive components, accessories, and aftermarket parts that were subject only to IEEPA tariffs may qualify. From yTrade customs data, motor cars (HS 8703) led at $187.3 billion (51.54%), while auto parts (HS 8708) accounted for $101.5 billion (27.94%).

• HS 8703 (motor cars, passenger vehicles): $187.3 billion (51.54%), primarily Section 232-covered and NOT eligible for IEEPA refund
• HS 8708 (vehicle parts and accessories): $101.5 billion (27.94%), mixed eligibility depending on whether parts fall under Section 232 or IEEPA
• HS 8704 (goods transport vehicles): $41.7 billion (11.48%), includes both Section 232-covered and non-covered categories
• HS 8701 (tractors): $10.8 billion (2.96%), may carry IEEPA-only tariff exposure in certain configurations
• HS 8716 (trailers, semi-trailers): $7.0 billion (1.94%), generally outside Section 232 scope and potentially IEEPA-eligible

HS Code	Description	Value (US$)	%	Quantity	%
8703	Motor cars and other motor vehicles; principally designed for the transport of persons (other than those of heading no. 8702), including station wagons and racing cars	187.3B	51.54%	7.6M	0.06%
8708	Motor vehicles; parts and accessories, of heading no. 8701 to 8705	101.5B	27.94%	11.5B	90.71%
8704	Vehicles; for the transport of goods	41.7B	11.48%	1.5M	0.01%
8701	Tractors; (other than tractors of heading no 8709)	10.8B	2.96%	201.2K	-
8716	Trailers and semi-trailers; other vehicles, not mechanically propelled; parts thereof	7.0B	1.94%	883.3M	6.96%

Automotive importers must separate IEEPA-covered parts from Section 232-covered finished vehicles and parts at the entry level. This is one of the most complex refund categories, and Grassi Advisors recommends working with trade counsel to properly classify affected entries.

Consumer Goods And Retail

U.S. apparel imports (HS 61 and HS 62) represent one of the most straightforward IEEPA refund categories, with combined import value of $82.12 billion in 2025, from yTrade data.

Total HS 61 (knitted or crocheted) imports reached $46.85 billion; total HS 62 (not knitted) reached $35.27 billion. Apparel is sourced heavily from IEEPA-affected Asian origins (Vietnam, Bangladesh, Indonesia, India) with minimal Section 232 or Section 301 overlap, making entries relatively clean for refund filing.

Retailers could be significant beneficiaries of IEEPA refunds given their high import volumes from affected countries.

• HS 6110 (jerseys, pullovers, cardigans, knitted): $16.1 billion, the single largest apparel import category
• HS 6204 (women's suits, dresses, skirts, not knitted): $13.9 billion, broad sourcing from IEEPA-affected Asian origins
• HS 6203 (men's suits, trousers, not knitted): $9.3 billion, similar multi-country sourcing pattern
• HS 6109 (T-shirts, singlets, knitted): $7.6 billion, high-volume fast-fashion category
• HS 6104 (women's suits, trousers, knitted): $7.2 billion, consistent demand across IEEPA-affected origins

HS Code	Description	Value (US$)	Quantity
6110	Jerseys, pullovers, cardigans, waistcoats and similar articles; knitted or crocheted	16.1B	255.5M
6204	Suits, ensembles, jackets, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear); women's or girls' (not knitted or crocheted)	13.9B	156.2M
6203	Suits, ensembles, jackets, blazers, trousers, bib and brace overalls, breeches and shorts (other than swimwear); men's or boys' (not knitted or crocheted)	9.3B	106.9M
6109	T-shirts, singlets and other vests; knitted or crocheted	7.6B	305.1M
6104	Suits, ensembles, jackets, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (not swimwear), women's or girls', knitted or crocheted	7.2B	136.4M

Generally Excluded Governed Categories

The following categories are not part of the IEEPA refund process. KPMG suggested importers should evaluate these separately:

• Steel, aluminum, and copper products (Section 232): Tariffed at 25-50% under separate authority. Not IEEPA. Not refundable.
• Finished automobiles and Section 232-covered auto parts: The 25% auto tariff is separately authorized and remains in force.
• Pharmaceuticals (Section 232, effective July-September 2026): Up to 100% on patented drugs. Separately authorized.
• Chinese-origin goods under Section 301: These tariffs predate IEEPA and remain under separate trade law authority.
• Products entering under USMCA: Canadian and Mexican goods claiming USMCA preferential treatment may not have paid IEEPA duties.
• Anti-dumping / countervailing duties: Product-specific enforcement measures unrelated to IEEPA.

How To Claim For U.S. Tariff Refund

CBP launched the CAPE portal on April 20, 2026 at 8:00 AM EST. According to CBP's official guidance, the process runs entirely through the ACE Secure Data Portal. Here is what importers need to do:

Step 1: Confirm ACE Portal Access

Register for an ACE Secure Data Portal account at ace.cbp.dhs.gov if you do not already have one.

Ensure you have the "Importer" sub-account, which is required to access the CAPE tab. Customs brokers need the Organizational Broker or Filer sub-account.

Step 2: Enroll In ACH For Electronic Refunds

Add your refund bank account information to your ACE Portal account. Without ACH enrollment, refunds cannot be processed. As of April 14, 2026, 56,497 importers had completed this step, qualifying them for $127 billion in refunds including interest.

Step 3: Identify Affected Entries

Pull entry records from ACE for the period when IEEPA tariffs were in effect (April 5, 2025 through February 24, 2026).

Flag entries where the tariff line includes an IEEPA Harmonized Tariff Schedule Chapter 99 provision. Separate IEEPA-only entries from entries where multiple tariff authorities overlap (for example, a product subject to both IEEPA and Section 301 duties).

Step 4: Determine Phase 1 Eligibility

Phase 1 of CAPE is limited to unliquidated entries and entries within 80 days of liquidation.

This accounts for roughly 82% of all IEEPA duty payments, or approximately $127 billion. Entries that have fully liquidated beyond the 80-day window will need to wait for Phase 2.

Step 5: File The CAPE Declaration

Access the CAPE tab in the ACE Portal and upload a CSV file listing the entry numbers for which refunds are requested. Each CAPE Declaration can include up to 9,999 entries. Multiple declarations may be submitted.

ACE will conduct 2 rounds of validation: the first checks the declaration itself, and the second validates individual entries. Valid entries will have IEEPA HTS Chapter 99 codes removed, duties recalculated, and entries updated to a new version.

Step 6: Preserve Documentation

Retain copies of original entry summaries (CBP Form 7501), duty payment records, broker correspondence, and CAPE submissions. If entries are rejected or require manual review, documentation will be essential. There are no new recordkeeping requirements for the CAPE Declaration beyond standard customs recordkeeping obligations.

Step 7: Monitor And Coordinate

Track refund activity using the REV-603 Trade Refund report in ACE Reports. Coordinate with your customs broker, particularly for complex entries with overlapping tariff authorities.

According to RSM, businesses with large import programs may need to coordinate across multiple brokers, reconcile records across multiple ports, and sequence filings to avoid locking out eligible entries with improperly structured declarations.

• Expected timeline: CBP has indicated that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further review.

Top US Import Countries With IEEPA Tariff Exposure

Trade volume and refund opportunity are not the same thing. A country can be a top-5 US import source and still have a minimal IEEPA refund pool — and vice versa. Three filters determine how much of a country's US-bound trade is actually refundable under CAPE:

1. IEEPA-specific rate (how much duty was collected per dollar of trade)
2. USMCA penetration (Mexican and Canadian goods entering under USMCA mostly avoided IEEPA duties)
3. Section 301 / Section 232 overlap (only the IEEPA portion is refundable; overlapping tariffs stay in force)

Where the biggest per-entry refunds are

Vietnam ($201.3B in 2025) is the standout refund opportunity. IEEPA rates on Vietnamese goods reached up to 46% — the highest tier in the 2025 reciprocal schedule. With minimal Section 301 overlap and no USMCA carve-out, a far higher share of duties paid on Vietnamese entries is refundable than on equivalent-value trade from Mexico or Canada. Apparel importers sourcing from Vietnam (HS 61-62) are especially well-positioned.

Taiwan,China ($205.0B) and India ($107.6B) follow the same pattern — high IEEPA exposure, negligible Section 301 overlap, no preferential trade agreement reducing the base. For Taiwan, electronics importers (HS 85) should see clean refund paths. For India, the opportunity is spread across industrial and agricultural HS codes.

Where volume looks big but refunds are smaller

Mexico ($539.0B, #1 source) and Canada ($393.0B, #2) — despite being the two largest US import partners, a large share of 2025 entries claimed USMCA preferential treatment and never paid IEEPA duties in the first place. The refund pool from these origins is proportionally much smaller than headline trade figures suggest.

Mainland China ($327.5B) — IEEPA duties were paid, but Section 301 tariffs predate and continue after IEEPA. Only the IEEPA portion of duty stacks on Chinese-origin entries is refundable; the Section 301 layer stays. Importers need entry-level duty breakdowns, not just country totals.

Mixed-exposure countries

Japan ($149.8B) and South Korea ($129.0B) — significant auto and electronics trade, but Section 232 auto tariffs remain at 25% on finished vehicles and covered parts. Refundability depends heavily on HS classification at the entry level.

Germany ($159.2B) and Ireland ($137.7B) — clean IEEPA exposure with no Section 301 overlap, but Ireland's pharmaceutical-heavy trade faces a new Section 232 pharma tariff (up to 100%) taking effect July-September 2026. The refund window on past IEEPA duties should be handled before the new Section 232 burden lands.

Country	Value (US$)	% of Total	Refund Profile
Mexico	$539.0B	15.34%	Low — high USMCA penetration
Canada	$393.0B	11.19%	Low — high USMCA penetration
Mainland China	$327.5B	9.32%	Partial — Section 301 overlap
Taiwan	$205.0B	5.84%	High — minimal overlap
Vietnam	$201.3B	5.73%	Highest — up to 46% IEEPA rate
Germany	$159.2B	4.53%	High — clean IEEPA exposure
Japan	$149.8B	4.26%	Mixed — Section 232 auto overlap
Ireland	$137.7B	3.92%	High — but pharma faces new 232
South Korea	$129.0B	3.67%	Mixed — Section 232 exposure
India	$107.6B	3.06%	High — minimal overlap

Bottom line for sourcing decisions: IEEPA refunds are a one-time recovery event. The tariff structure that remains — Section 232, Section 301, Section 122 — continues to shape landed cost going forward. Importers heavy in Vietnam and India stand to recover the most from CAPE filings. Importers heavy in China, Japan, and Korea need to assume most of their tariff burden persists.

For importers evaluating whether to adjust sourcing in response to the post-IEEPA tariff landscape, yTrade's capabilities can help identify alternative suppliers shipping the same HS codes from lower-tariff origins.

How yTrade Helps Importers Navigate The Post-IEEPA Tariff Landscape

yTrade does not process tariff refund claims.

What yTrade does is give importers the customs-direct trade data foundation to understand which products, suppliers, and trade lanes carry the most exposure under the tariff structure that remains after IEEPA removal, and where to find alternatives.

• Map exposed SKUs and suppliers: Identify which HS codes and supplier countries in your portfolio are still subject to Section 232, Section 301, or Section 122 tariffs after IEEPA refunds clear.
• Identify countries and suppliers linked to affected entries: Cross-reference your IEEPA entry list against yTrade's customs-direct records to understand which trade relationships were most impacted.
• Model sourcing alternatives: Search yTrade's 200+ country dataset to find suppliers shipping the same HS codes from lower-tariff origins, helping optimize landed cost under the remaining tariff regime.
• Monitor category exposure by product and trade lane: Track how import volumes and supplier activity are shifting across your product categories as other importers adjust sourcing in response to the new tariff structure.

Ready to map your tariff exposure against customs-direct trade data? Request a demo of yTrade and see how the platform handles your specific HS codes, sourcing countries, and supplier portfolios.

Frequently Asked Questions

Who is eligible to file for an IEEPA tariff refund?

Only the Importer of Record, or a licensed customs broker filing on their behalf, can submit a CAPE Declaration. Consumers are not eligible. Importers need an ACE Secure Data Portal account with the "Importer" sub-account; brokers need the Organizational Broker or Filer sub-account.

How long will it take to receive my refund?

CBP has indicated that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further review. Refunds are paid via ACH, so bank account enrollment in the ACE Portal is required before any refund can be processed.

Which tariffs are NOT refundable through CAPE?

CAPE only covers IEEPA-imposed tariffs. The following remain in force under separate legal authorities and are not refundable: Section 232 tariffs on steel, aluminum, copper (25-50%), autos and auto parts (25%), and pharmaceuticals (up to 100%, effective July-September 2026); Section 301 tariffs on Chinese-origin goods; the Section 122 10% global surcharge; and anti-dumping or countervailing duties.

Can I claim a refund if my goods came from China?

Partially. Chinese-origin entries were typically subject to both IEEPA reciprocal tariffs and Section 301 tariffs. Only the IEEPA portion of the duty is refundable — Section 301 duties predate IEEPA and remain under separate trade law authority.

What if my entries came in under USMCA?

USMCA-qualifying Canadian and Mexican goods may not have paid IEEPA duties in the first place, so there is nothing to refund on those entries. This is why Mexico and Canada — despite being the #1 and #2 sources of US imports — have a proportionally smaller IEEPA refund pool than countries like Vietnam.