IEEPA Tariff Refund Portal Opens Today: $127 Billion Available for Importers

U.S. Customs and Border Protection launched the Consolidated Administration and Processing of Entries (CAPE) tool on Monday, April 20, 2026, opening the first formal channel for American importers to claim refunds on tariffs ruled unconstitutional by the Supreme Court in February. Phase 1 covers up to $127 billion in eligible duties, according to CBP guidance, making this one of the largest government refund operations in recent trade history.

The launch follows a February 20 Supreme Court ruling in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) does not grant the president authority to impose tariffs. That decision invalidated the emergency tariff regime that had been a central plank of the Trump administration’s trade policy since early 2025, leaving billions of dollars in collected duties in legal limbo pending a mechanism to process refunds.

What the CAPE Portal Does

CAPE is integrated into the existing Automated Commercial Environment Secure Data Portal (ACE), which customs brokers and importers already use for trade filings. Beginning April 20, importers of record and their brokers can log into the ACE Portal, navigate to the new CAPE tab, and upload a comma-separated values file — referred to as a “CAPE Declaration” — containing the relevant entry data.

The system is designed to consolidate refunds across multiple entries rather than processing them one by one, which CBP described as a key efficiency improvement over traditional entry-level protest procedures. Importers with hundreds or thousands of affected entries will be able to batch-submit claims rather than filing individual protests for each.

CBP estimates that once a submission is accepted and passes compliance review, refunds will be issued electronically within approximately 60 to 90 days, inclusive of statutory interest.

Phase 1 Scope: What Qualifies

Phase 1 of CAPE covers two categories of entries:

  • Unliquidated entries: Entries that have not yet been finalized by CBP. These are generally more recent filings where the duty liability is still open.
  • Liquidated entries within 80 days of liquidation: Entries that have been finalized but where the 80-day window for filing a standard protest has not yet elapsed.

Together, these two categories account for approximately 82% of IEEPA duty payments, or $127 billion of the estimated $166 billion total collected under the invalidated tariff regime, according to CBP’s published figures.

Entries that fall outside Phase 1 — older liquidated entries beyond the 80-day protest window — are expected to be addressed in subsequent phases, though CBP has not yet published a timeline for those releases.

Context: The Supreme Court Ruling

The February ruling in Learning Resources, Inc. v. Trump was the culmination of multiple legal challenges that had been working through the federal courts since 2025. Plaintiffs argued that the administration had stretched IEEPA beyond its statutory limits by using it as a general-purpose tariff authority rather than for the narrower emergency economic purposes Congress intended when it passed the law in 1977.

The Court agreed, in a 6-3 decision authored by Chief Justice Roberts, finding that the text and history of IEEPA do not support broad presidential tariff-setting authority. The ruling did not affect tariffs imposed under other statutory authorities — Section 232 (national security), Section 301 (unfair trade practices), and the 90-day universal 10% tariff imposed under Section 122 of the Trade Act of 1974 remain in effect.

The administration had signaled in advance of the ruling that it was preparing contingency measures. Shortly after the decision, Trump announced a universal 10% tariff under Section 122, to remain in force until July 24, 2026. That tariff is also facing legal challenges, though it has not been stayed by any court as of April 20.

For background on how the tariff landscape evolved this year, see Trump’s 50% tariff threat against China and countries arming Iran, which illustrates how the administration has continued to pursue aggressive trade measures through alternative statutory authorities even as IEEPA-based tariffs unraveled.

What Importers Need to Do

Trade attorneys and customs consultants have published detailed guidance since CBP released the CAPE filing instructions in mid-April. The core steps are:

  1. Identify eligible entries. Review import records to identify entries where IEEPA duties were paid. This requires separating IEEPA-specific duty payments from other tariff categories, which may require coordination with customs brokers who have detailed entry data.

  2. Verify liquidation status. Confirm whether each entry is unliquidated or within the 80-day protest window. Entries outside these categories are not eligible for Phase 1 and will need to wait for later phases or alternative refund mechanisms.

  3. Prepare the CAPE Declaration CSV. The CSV must include specific fields as defined in CSMS #68315804, the CBP message that formalized the Phase 1 instructions. Errors in the CSV format can result in rejected submissions.

  4. Submit through the ACE Portal. The submission goes through the CAPE tab in ACE. Importers without ACE access can work through a licensed customs broker.

  5. Monitor for correspondence. CBP may issue requests for additional documentation during the compliance review period. Failing to respond promptly can delay or forfeit the refund.

Importers are also being advised to retain supporting documentation — original import records, payment confirmations, and entry summaries — as CBP is conducting spot audits of submissions.

Economic Significance

The $127 billion in Phase 1 refunds represents a substantial transfer from the federal government back to the private sector. For context, the entire federal customs revenue for fiscal year 2024 was approximately $90 billion, meaning the refund pool exceeds a full year of normal customs collections.

The refunds are not all profit for importers. Many businesses that absorbed higher tariff costs passed some of those costs on to customers through price increases. In those cases, the refund accrues to the importer rather than to the end consumer, which has prompted some consumer advocates to argue that the refund mechanism is incomplete without a corresponding mechanism to return costs to final buyers.

The Federal Reserve is watching the refund flow carefully. Several hundred billion dollars returning to business balance sheets over the next 12 to 18 months — as Phase 1 and later phases process — could provide a modest economic stimulus, though the magnitude is uncertain and depends on how businesses deploy the funds.

Tariff Landscape Going Forward

The CAPE launch resolves the backward-looking refund question for Phase 1 entries but does not resolve the broader uncertainty about what tariff regime will govern future imports. Key variables include:

  • Section 122 litigation: Legal challenges to the universal 10% tariff are pending. If those succeed, a second large refund program could eventually be required.
  • Trump-Xi summit (May 14-15): A planned meeting in Beijing could produce a negotiated trade framework for US-China commerce. How that interacts with existing Section 301 tariffs on Chinese goods is unclear.
  • Congressional action: Some legislators have introduced bills to reassert congressional authority over tariff-setting, though none have advanced far in the current session.

For importers navigating this environment, the CAPE portal opening is a concrete step forward — but it covers only the most recent IEEPA tariff period, not the full spectrum of trade costs incurred since early 2025. For a broader look at the tariff timeline and its economic costs, including the Liberation Day tariff anniversary, the context stretches back more than a year and remains unresolved.

The Bottom Line

The April 20 CAPE launch gives importers a concrete, CBP-administered pathway to recover tariff payments that the Supreme Court ruled were unlawfully collected. With $127 billion eligible in Phase 1 and a 60-to-90-day refund timeline, the practical benefit is significant for businesses that paid IEEPA duties and maintained the records needed to file. The window is time-sensitive — entries must be unliquidated or within 80 days of liquidation to qualify — making the April 20 launch date a meaningful deadline for companies that have been waiting to act.

Sources

  • U.S. Customs and Border Protection, CAPE tool instructions and IEEPA Duty Refunds portal, April 2026
  • CBP CSMS #68315804, Phase 1 CAPE deployment instructions, April 2026
  • Norton Rose Fulbright, “CBP issues tariff refund instructions,” April 2026
  • RSM US, “IEEPA tariff refund portal opens April 20: What importers need to know,” April 2026
  • FreightFigures, “CBP CAPE Tool Goes Live April 20, 2026,” April 2026
  • Skadden, “Tariff Refund Mechanism Takes Shape After Supreme Court’s IEEPA Ruling,” April 2026
  • CBS News, “Trump administration set to launch tariff refund portal,” April 2026