$166 billion in tariff refunds is being returned to U.S. importers. Find out if your business qualifies.

What is this opportunity?

Between early 2025 and early 2026, the Trump administration imposed sweeping tariffs on goods imported from China, Canada, Mexico, and dozens of other trading partners. These levies were imposed under the International Emergency Economic Powers Act (IEEPA) — a 1977 law that gives the president broad authority to regulate foreign commerce in a declared national emergency. Businesses that imported goods during that window paid billions in IEEPA tariff surcharges on top of ordinary customs duties.

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that IEEPA does not authorize the imposition of sweeping tariffs. The Court held that Congress never granted the president that power when it passed IEEPA in 1977, and that the tariffs violated the separation of powers. Within weeks, the Court of International Trade ordered U.S. Customs and Border Protection to refund the unlawfully collected duties.

CBP responded by launching the CAPE (Customs Automated Processing Environment) portal on April 20, 2026 — a system within the existing ACE (Automated Commercial Environment) platform that allows importers of record to file structured refund claims. Phase 1 covers entries finalized on or before January 30, 2026. Importers who act quickly may receive refunds within 60 to 90 days of approval.

Why it matters now

Interest on unliquidated duty refunds accrues at a statutory rate — currently estimated at roughly $22 million per day across all affected importers. That interest accumulates in your favor, but only for entries that are actually filed. Entries that miss Phase 1 may face additional complexity in subsequent phases, including potential reliquidation disputes.

The administration has signaled it may pursue appeals through alternative legal theories, including potential Section 301 redesignations for some tariff categories. While legal experts view outright reversal of the Supreme Court ruling as extremely unlikely, importers who delay filing assume the risk of additional procedural complications.

Phase 1 covers the most straightforward category: unliquidated entries and entries liquidated within the prior 80-day window. Future phases, covering protested entries, AD/CVD interactions, and drawback claims, are expected to carry more documentation complexity and potentially longer processing timelines. Learn more about Phase 1 vs. future phases →

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