Which entries are eligible for an IEEPA refund
CAPE Phase I is narrow. If you're not sure whether an entry qualifies, err on the side of including it — CBP's validator will flag ineligible entries rather than rejecting your whole filing — but don't expect every dollar you paid in duties back.
Eligible
- Duties collected under IEEPA-based tariff actions the Supreme Court ruled unlawful in Feb 2026
- IEEPA duties on entries filed during the period covered by the ruling
- Amended entries where the IEEPA-based duty is separately identified
Not eligible (CAPE Phase I)
- Section 301 China tariffs (separate legal basis, not covered by CAPE)
- Section 232 steel and aluminum tariffs
- Ordinary MFN (most-favored-nation) duties
- Merchandise Processing Fee (MPF) and Harbor Maintenance Fee (HMF)
- Anti-dumping and countervailing duties
Not sure?
If your 7501 or broker statement itemizes duties by type, look for the line labeled IEEPA (sometimes grouped under "Other" with a HTS Chapter 99 tariff code). That's the refundable piece.
A licensed customs broker can run a duty analysis across your entries and tell you exactly what's recoverable. If total IEEPA duties paid are above ~$250k, it's usually worth the fee.
Ready to clean your list? Open the CAPE Filing Helper.