When the Supreme Court ruled 6–3 in Learning Resources v. Trump that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded presidential authority, Customs and Border Protection was left holding roughly $166 billion in duties it had no legal basis to collect.
Within weeks, CBP stood up the Customs Assessed Payments Eligibility (CAPE) portal — the mechanism by which importers of record from 2018 onward can file to recover the IEEPA-tagged portion of duties paid. The filing window is 180 days from portal open. Miss it and the claim is gone.
This post walks through:
Any entity listed as Importer of Record (IOR) on a CBP Form 7501 between 2018 and 2026 where any portion of the duty assessment was attributed to an IEEPA action. That includes the original Section 301 “China tariffs” that were re-issued under IEEPA authority after 2019, the Section 232 steel/aluminum extensions, and the 2025 universal baseline tariffs.
If your customs broker filed the 7501 under your EIN, the IEEPA duty line items are visible in your ACE portal entry summary export.
Approximately 330,000 US companies have at least one qualifying entry, per CBP’s preliminary CAPE population estimate. The largest concentration is in consumer electronics, Amazon FBA sellers, auto parts, and apparel.
Before you spend a cent on a customs broker engagement, you can narrow your expected refund to a mid-range using three inputs:
1. Total duties paid in the 2018–2026 window — line 6 on each entry summary, aggregated.
2. Country-of-origin mix — the IEEPA-attributable share is highest for China-origin entries and near-zero for USMCA qualifying goods.
3. HTS classification stacking — entries that stacked Section 301 + Section 232 + IEEPA see the largest per-entry refund.
The IEEPA refund calculator on Tariff Refund Credits takes those three inputs and returns a probability-weighted low / mid / high estimate. The methodology is published on the methodology page.
Typical results we’ve seen:
| Program | What it recovers | Who files |
|———|——————|———–|
| IEEPA refund (CAPE) | Duties paid under IEEPA authority 2018–2026 | Importer of record, 180-day window |
| Section 301 protest | Section 301 duties on protest-eligible entries | Any importer within 180 days of liquidation |
| Section 232 refund | Section 232 duties on excluded HTS codes | Importer on CBP Form 19 protest |
| Duty drawback | Up to 99% of duties on goods later exported or destroyed | Any exporter/destroyer, 5-year window |
Many importers qualify for more than one program simultaneously. The tariff stacking calculator models overlap.
CBP regulation 19 CFR 111 reserves the act of “transacting customs business” — which includes filing for refund on behalf of another party — to licensed customs brokers. Tariff Refund Credits is a lead-generation service that connects importers with licensed customs broker partners. It is not itself a customs broker, does not file on behalf of importers, and does not give legal or customs advice.
The platform is free to use through the estimation and eligibility phase. Engagement with a broker partner is a standard success-fee arrangement — typically 20–25% of recovered funds — disclosed on the pricing page.
1. Estimate your refund with the IEEPA refund calculator
2. Take the 60-second qualification quiz
3. If you qualify, book a 20-minute strategy call with a licensed broker partner
4. Review the full process in the guides library
All estimates are preliminary and subject to CBP adjudication. Tariff Refund Credits provides estimation tools and broker matching only — customs business is performed exclusively by the broker partner under 19 CFR 111.
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