Telep IO Tariff Refund Desk

Recover IEEPA duties through CBP's CAPE process

The Supreme Court held that IEEPA does not authorize tariffs. CBP now accepts refund requests in the ACE Portal. This site explains the process in plain English and helps you check which of your entries qualify today.

Check eligibilityDIY Readiness Report, $49
Information only. Not legal or customs brokerage advice.

What the official sources say

Every rule on this site comes from a primary source. Read them directly.

Supreme Court, February 20, 2026

Learning Resources, Inc. v. Trump, No. 24-1287, decided with Trump v. V.O.S. Selections, No. 25-250.

"IEEPA does not authorize the President to impose tariffs."

supremecourt.gov opinion (PDF)

CBP: IEEPA Duty Refunds

"Importers of Record (IORs) and Customs brokers are able to file a CAPE Declaration, using a Comma-Separated Values (.CSV) file, through their web-based ACE Secure Data Portal (ACE Portal) account."

cbp.gov IEEPA Duty Refunds page

CBP CSMS messages

CAPE launched April 20, 2026 (CSMS 68340863). Since June 29, 2026, it also accepts entries flagged for reconciliation with no reconciliation entry on file (CSMS 69035485).

CSMS 68340863 · CSMS 69035485 · CAPE error definitions (PDF)

Recent court developments

Last reviewed Oct 30, 2026. These affect entries liquidated more than 80 days ago. Summaries only; read the filings.

CAPE Phase 3, October 6, 2026

In a court declaration, CBP said Phase 3 "covers finally liquidated entries filed by plaintiffs for which the Court has ordered reliquidation." It is open only to importers who sued at the Court of International Trade (CIT) and are covered by a reliquidation order. CBP opens access on a rolling basis and notifies plaintiffs through their counsel. As of its October 26 declaration, plaintiffs "that submitted a valid IOR number before August 14, 2026" could file.

Declarations of Brandon Lord, CBP, Freestyle World, Inc. v. United States, CIT No. 26-01088: ECF 58 (Oct 6) · ECF 65 (Oct 26) (court record copies via CourtListener)

Class certified, October 8, 2026

The CIT certified a class of "All importers of record who paid duties imposed by the Challenged Tariff Orders between February 1, 2025, and February 19, 2026, excluding any entity that has separately filed an action seeking to recover IEEPA duties payments." Membership is mandatory. The order certifies the class only; the court noted "there has been no merits determination" and it has not yet ordered refunds for class members.

CIT Slip Op. 26-123 (cit.uscourts.gov)

Protested entries, October 29, 2026

The CIT stated its understanding that plaintiffs in individual cases may process refunds for finally liquidated entries that are the subject of a protest in Phase 3 "(1) even if the protest has not been withdrawn, and (2) no matter if the protest relates exclusively to IEEPA duties or includes other issues as well." This applies to plaintiffs, not to importers who have not sued.

CIT Order, No. 26-01088, ECF 66 (Oct 29)

Federal Circuit appeal pending

The government appealed the CIT's broader refund orders (V.O.S. Selections v. United States, Fed. Cir. No. 26-1895). The CIT's October 8 opinion says the appeal is briefed and a decision "will be rendered in due course." The outcome could affect refunds for importers who have not sued.

Fed. Cir. order, No. 26-1895 (cafc.uscourts.gov) · Slip Op. 26-123

If your entries liquidated more than 80 days ago and you have not sued, CAPE does not currently accept them. Phase 3 is for plaintiffs only. You may be within the certified class, but that does not yet provide a refund. Deadlines to bring your own case may apply. Talk to a trade attorney about your situation. Information only. Not legal or customs brokerage advice.

The refund process, step by step

Based on CBP guidance. Only the Importer of Record or the licensed broker who filed the entries may file a CAPE Declaration.

  1. Set up ACE Portal access. Your Importer of Record number needs an ACE Portal account.
  2. Enroll in ACH refunds. CBP pays IEEPA refunds electronically and needs refund bank details in ACE.
  3. List your IEEPA entries. Find entries with IEEPA Chapter 99 duty lines on CBP Form 7501 or in ACE reports.
  4. Check each entry's status. Current CAPE phases accept unliquidated entries and entries liquidated no more than 80 days ago. Entries on an open or suspended protest are rejected. Older entries: see Recent court developments.
  5. Upload the CAPE Declaration. In the CAPE tab, use the Upload button template. CBP says it needs only the list of entry numbers, up to 9,999 per declaration.
  6. Fix validation errors. Review CAPE File Upload History. A filed declaration cannot be cancelled or have entries removed.
  7. Receive the refund. CBP says valid refunds are generally issued within 60 to 90 days after acceptance, with interest under 19 U.S.C. 1505. A protest disputing the refund amount is due within 180 days of liquidation or reliquidation.

Free eligibility check

Seven short questions about one entry or a group of similar entries. Nothing is stored or sent anywhere.

Leave blank if the entry has not liquidated.

DIY CAPE Readiness Report

For importers filing their own CAPE Declaration. You stay in control and file in your own ACE account.

$49 one time, per report
  • Screening of every entry against CBP's published CAPE rejection rules: liquidated more than 80 days ago, open or suspended protest, reconciliation on file, and excluded entry types
  • Days remaining in the 80 day window and the 180 day protest date for each entry
  • A CAPE ready CSV of entries that pass
  • An ACE filing checklist and cited official sources

Secure payment by Stripe. The report appears immediately after payment. It is a screening aid; CBP's validation in ACE is final.

Upload your entries

Paste a CSV with this header row: entry,type,liquidated,protest,recon09,ieepa_duty. Use YYYY MM DD dates (blank if not liquidated) and yes or no for protest and recon09. Up to about 500 entries.

Information only. Not legal or customs brokerage advice.

Frequently asked questions

Who can file a CAPE Declaration?

Only the Importer of Record for the listed entries, or the licensed customs broker who filed those entries on its behalf, according to CBP.

What does the CSV need to contain?

CBP says the CAPE Declaration is the list of entries for which refunds of IEEPA duties are requested, and "CBP does not require any other information in the .CSV file." Use the template from the Upload button in the ACE Portal CAPE tab.

My entry liquidated more than 80 days ago. What now?

Phases 1 and 2 of CAPE reject entries liquidated more than 80 days ago. CAPE Phase 3, deployed October 6, 2026, accepts finally liquidated entries only for importers who sued at the Court of International Trade and are covered by a reliquidation order. On October 8, 2026, the court certified a class of importers who paid IEEPA duties from February 1, 2025 to February 19, 2026 and did not sue, but that order does not itself provide refunds, and a Federal Circuit appeal (No. 26-1895) is pending. Talk to a trade attorney about whether to file your own case or rely on the class. See Recent court developments.

Am I in the class?

The certified class is "All importers of record who paid duties imposed by the Challenged Tariff Orders between February 1, 2025, and February 19, 2026, excluding any entity that has separately filed an action seeking to recover IEEPA duties payments" (Slip Op. 26-123). Whether your company fits is a legal question for a trade attorney.

How long does a refund take, and is interest paid?

CBP says valid refunds are generally issued within 60 to 90 days after the declaration is accepted, unless further review is needed, and that interest is included under 19 U.S.C. 1505. Refunds may be netted against amounts owed on the entry or offset against debts to the United States.

Can I change a declaration after filing?

No. CBP says once filed, you cannot remove entries from a CAPE Declaration or cancel it. File any unrelated post summary corrections first.

Do you file for me or need my ACE login?

No. We never ask for ACE credentials or bank details. CBP warns that scammers are targeting importers during the refund process.

Is this legal or customs brokerage advice?

No. Telep IO LLC is not a law firm or a licensed customs broker. This site is information only.

Information only. Not legal or customs brokerage advice. Last reviewed Oct 30, 2026.