IEEPA Reciprocal Tariff
Recovery
Calculate Your Tariff Refunds
with Clarity
Upload your Entry Summary (ES-003) CSV from CBP's ACE portal to instantly estimate your IEEPA tariff refund potential — filtered by HTS code and CAPE Phase eligibility.
1
Upload Your Entry Summary Data
Not sure about the file format?
Download the sample ES-003 CSV to see the expected column structure, then try it live.
Drag & Drop Your ES-003 Entry Summary
Export your Entry Summary report from CBP's ACE portal, then upload it here
to instantly see your
IEEPA refund potential by entry and deadline status.
Drag & Drop supported · CSV only
⚠️ Disclaimer: This calculator provides an estimate only and is for
informational purposes. Results are based solely on the information entered and certain simplifying
assumptions. It is not a determination of eligibility, a guarantee of refund, or a binding calculation. Refund
rights, procedures, and amounts remain subject to government review, statutory requirements, filing deadlines,
and potential legal developments. Use of this calculator does not constitute legal or tax advice and does not
create an attorney-client relationship. You should consult qualified counsel regarding your specific
circumstances.
Analyzing your entries…
Potential Refund Value
$0
↑ 0% of total duties paid
Total Entered Value
$0
Total Duties Paid
$0
Across all tariff types
Non-Refundable
$0
Base duties / expired entries
Deadline Status
Refund Eligibility by CAPE Phase
Phase eligibility is determined by each entry's estimated liquidation date (~314 days after entry date). Phase 1 covers unliquidated entries and entries liquidated within the last 80 days (19 U.S.C. §1501). Phase 2 guidance is pending — register your ACH account now while you wait.
Phase 1 Eligible — unliquidated or liquidated ≤80 days ago. File CAPE Declaration now via ACE.
Potentially Barred — outside Phase 1 window. Phase 2 guidance pending from CBP.
Status tags: 🟢 Phase 1 = eligible now — file CAPE Declaration via ACE · ⬜ Barred = outside Phase 1 window, monitor CBP.gov/CAPE for Phase 2 launch
Entry Detail
Highest Value Refund Opportunities
| Entry Number | Entry Date | Est. Liquidation | IEEPA Duty | Status |
|---|
Next Steps
How to Claim Your Refunds
1
Confirm Phase 1 Eligibility
Verify liquidation status in ACE. Phase 1 covers entries that are unliquidated or liquidated within the last 80 days (19 U.S.C. §1501). Estimated liquidation = entry date + 314 days — confirm the actual date in ACE.
2
File CAPE Declaration
Generate your CAPE Declaration CSV from the calculator and file via CBP's ACE portal. Your existing broker can file on your behalf with a POA. Refunds are issued via ACH approximately 60–90 days after acceptance.
3
Register ACH & Monitor Phase 2
Ensure your ACH bank account is enrolled in ACE — CBP requires this before issuing any refund. Monitor CBP.gov/CAPE for Phase 2 guidance covering entries outside the Phase 1 window.
Ready to move forward? Book a free consultation with our customs specialists to begin your refund claim.
Claim Your Potential Refund⚠️ Disclaimer: This calculator provides an estimate only and is for
informational purposes. Results are based solely on the information entered and certain simplifying
assumptions. It is not a determination of eligibility, a guarantee of refund, or a binding calculation. Refund
rights, procedures, and amounts remain subject to government review, statutory requirements, filing deadlines,
and potential legal developments. Use of this calculator does not constitute legal or tax advice and does not
create an attorney-client relationship. You should consult qualified counsel regarding your specific
circumstances.
Reference
Guide
IEEPA Tariff Catalog
Chapter 99 HTSUS codes related to IEEPA reciprocal tariffs, sourced directly from CBP CSMS bulletins.
Tariff-Imposing Codes
Potentially Refundable — subject to filing deadlines and CBP
review
| HTS Code | Rate | Description | Effective | Source | Status |
|---|---|---|---|---|---|
| 9903.01.25 | 10% | Universal reciprocal tariff — all countries (baseline) | Apr 5, 2025 | CSMS #64649265 | Refundable |
| 9903.01.43–.62 | Varies | Country-specific elevated rates (20 countries) | Apr 9, 2025 | CSMS #64680374 | Refundable |
| 9903.01.63 | 34% (suspended) | China-specific rate — announced 34% but superseded by 9903.01.25 (10%) in practice; 9903.01.63 still appears on some entry summaries | Apr 9, 2025 | CSMS #64680374 | Refundable |
| 9903.01.64–.76 | Varies | Additional country-specific reciprocal rates | Apr 9, 2025 | CSMS #64680374 | Refundable |
| 9903.02.02–.71 | Varies | Per-country rates under new Executive Order (70 country codes) | Aug 7, 2025 | CSMS #65829726 | Refundable |
| 9903.01.20 & .24 | 10% | IEEPA Fentanyl duties on China (two tranches) | Feb 4 & Mar 4, 2025 | EO 14195 | Refundable* |
| 9903.02.01 | 40% | Transshipment evasion penalty rate | Aug 7, 2025 | CSMS #65829726 | Case-by-case |
* Fentanyl duties (9903.01.20 & .24) — imposed under separate Executive Orders (EO
14195 / EO 14200), not the Liberation Day tariffs. Their refundability under the SCOTUS ruling is
not confirmed and is pending further CBP guidance. Do not include these in your refund
estimate without consulting a customs broker.
Exemption Codes
NOT Refundable — Exempt, Expired, or
Ineligible
| HTS Code | Description | Notes | Status |
|---|---|---|---|
| 9903.01.26 | Canada — USMCA qualified goods | Duty-free at border | Exempt |
| 9903.01.27 | Mexico — USMCA qualified goods | Duty-free at border | Exempt |
| 9903.01.28 | In-transit exception (loaded pre-Apr 5) | Expired Jun 16, 2025 | Expired |
| 9903.01.29 | Column 2 countries (Belarus, Cuba, NK, Russia) | Higher Column 2 rates apply | Exempt |
| 9903.01.30 | Humanitarian donations (food, clothing, medicine) | Duty-free | Exempt |
| 9903.01.31 | Informational materials (publications, media) | Duty-free | Exempt |
| 9903.01.32 | Annex II exclusions (pharma, semis, copper, lumber) | Expanded Apr 11 & Nov 2025 | Exempt |
| 9903.01.33 | Section 232 products (steel, aluminum, autos) | Subject to Sec 232 duties instead | Exempt |
| 9903.01.34 | US-origin content portion (≥20% US value) | Only non-US content taxed | Exempt |
| 9903.02.78 | Agricultural exclusions (Nov 2025 expansion) | 237 HTS categories | Exempt |
Sources
Key CBP Guidance
CBP CAPE Portal
↗
cbp.gov — CAPE portal launched April 20, 2026. Phase 1 CAPE Declarations filed via ACE. Refunds via ACH ~60–90 days. Phase 2 guidance pending.
CSMS #64649265
↗
Reciprocal Tariffs, April 5, 2025 Effective Date — baseline 10% universal rate
CSMS #64680374
↗
Reciprocal Tariffs, April 9, 2025 — country-specific elevated rates
CSMS #65829726
↗
Reciprocal Tariff Updates Effective August 7, 2025 — new per-country 9903.02.xx
codes
CBP IEEPA FAQ
↗
cbp.gov — Frequently Asked Questions on IEEPA reciprocal tariffs, ongoing updates
SCOTUS — Feb 20, 2026 ↗
Learning Resources v. Trump — IEEPA tariffs ruled unlawful 6–3. EO terminating
them signed same day.
IEEPA Refund Recovery
Refund Handbook
Everything you need — from legal background to filing your claim. Select a topic from the menu to get started.
Important: A favorable ruling does not guarantee a refund. Refund eligibility depends
on timely filings, procedural compliance, and final court outcomes. Government agencies may contest or delay
refunds.
01Context
Legal Background
Why the IEEPA refund opportunity exists, what changed legally, and which tariffs may be refundable.
What Are IEEPA Tariffs?
The International Emergency Economic Powers Act (IEEPA) granted the President
authority to impose tariffs during a declared national emergency. Starting April 2025, broad
"reciprocal" tariffs were imposed on imports from ~90 countries — ranging from 10% to over 100%
depending on country of origin.
April 2, 2025
Executive Order — "Liberation Day"
Reciprocal IEEPA tariffs imposed on imports from ~90 countries. Chapter
99 supplemental HTS codes (9903.xx.xx) added to entry summaries to identify the IEEPA component.
April – December 2025
Duties Collected by CBP
CBP collects IEEPA duties at the border. Importers pay — without
knowing the legal basis would later be struck down.
Late 2025
Legal Challenges at CIT
Multiple importers file suit at the Court of International Trade,
arguing IEEPA does not grant tariff authority — a power reserved for Congress.
February 20, 2026
SCOTUS Rules IEEPA Tariffs Unlawful ✓
The Supreme Court ruled that IEEPA does not grant tariff authority, while decisions regarding potential tariff refunds remain with the lower courts.
April 20, 2026
CBP Launches CAPE Portal ✓
CBP launches the Consolidated Administration and Processing of Entries (CAPE) portal in ACE — the structured mechanism for importers to claim IEEPA duty refunds. Phase 1 covers unliquidated entries and entries liquidated within the last 80 days (19 U.S.C. §1501). Refunds via ACH in ~60–90 days.
Which Tariffs May Qualify for a Refund?
✅ Potentially Refundable
- Reciprocal tariffs (9903.01.25, .43–.76)
- Baseline 10% universal tariff (9903.01.25)
- China-specific IEEPA (9903.02.02–.71)
- Early IEEPA fentanyl codes (9903.01.20 & .24)
❌ Not Refundable
- Section 301 China tariffs (9903.88.xx)
- Section 232 steel & aluminum (9903.80.xx)
- Base MFN / standard duties
- USMCA / Canada / Mexico goods
- Entries outside Phase 1 window (Phase 2 TBD)
Fentanyl-related tariffs (separate Executive Order) are pending CBP guidance —
their
refundability is not yet confirmed. The calculator flags these separately.
02Qualification
Eligibility Checklist
Work through each criterion. You need to satisfy all of them to have a potentially recoverable refund claim. Click each item to mark it.
Eligibility Criteria
0
/ 6 checked
✓
You were the Importer of Record (IOR)
Refunds go to whoever paid the duty. If you purchased DDP from a foreign
supplier, they may be the IOR — not you.
✓
Goods entered between April 2, 2025 and February 20, 2026
IEEPA tariffs first applied April 2, 2025; the SCOTUS ruling took effect
February 20, 2026. Entries outside the April 2, 2025 – February 20, 2026 window have no IEEPA
duty component to refund.
✓
Entry contains a refundable Chapter 99 HTS code
Your entry summary must include a 9903.xx.xx supplemental code in the
refundable range. Run your ES-003 through the calculator to verify instantly.
✓
Goods were not USMCA-origin (Canada or Mexico)
USMCA-qualifying goods were exempt from IEEPA tariffs — if they didn't pay
IEEPA duties, there's nothing to refund.
✓
At least one entry is within an active CAPE Phase 1 window
Entry must be unliquidated or liquidated within the last 80 days (19 U.S.C. §1501). See the Deadlines section for details. Phase 2 coverage for older entries is pending CBP guidance.
✓
You have access to your entry summary data
You'll need your ES-003 export from ACE or equivalent from your broker.
See Section 04 for the step-by-step export guide.
Not sure? Upload your ES-003 to the Refund Calculator — it checks every entry automatically
and shows you exactly what qualifies.
03Time-Sensitive
Critical Deadlines
Two separate legal windows exist for recovering IEEPA duties. Which applies to each entry depends on whether CBP has liquidated it yet.
CAPE portal is live — but not all entries are covered yet. CBP launched CAPE on April 20, 2026. Phase 1 covers unliquidated entries and entries liquidated within the last 80 days. Phase 2 (older liquidated entries) has not launched. The Phase 1 window rolls daily — file now and register your ACH account.
Phase 1 — CAPE Declaration
Unliquidated or Liquidated ≤80 Days Ago
File a CAPE Declaration CSV via ACE. No Form 19. No attorney required. Refund via ACH ~60–90 days.
Rolling 80-day window (19 U.S.C. §1501)
Phase 2 — Pending CBP Guidance
Liquidated >80 Days Ago
CBP Phase 2 procedures not yet published. Ensure ACH enrolled and ACE account active. Monitor CBP.gov/CAPE.
Launch date TBD — register ACH now
How to Calculate
Your Deadlines
For any entry — compute all three dates (always use today's date as
your reference — status changes daily)
Est. Liquidation Date
Entry Date + 314 days
Verify the actual date in ACE — always use the real date
Phase 1 Window
Unliquidated or
Liquidated ≤80 days ago (rolling)
Liquidated ≤80 days ago (rolling)
19 U.S.C. §1501 — window moves daily
Phase 2 Window
Liquidated >80 days ago
CBP guidance pending — register ACH now
04Data
Export
Pulling Your ES-003
Step-by-step guide to exporting the right report from CBP's ACE Secure Data Portal. Takes 5–10 minutes.
🔐
ACE Login
CBP portal credentials. Ask your Trade Account Owner if you don't have
access.
📅
Date Range
April 2025 to today — covers all IEEPA-period entries.
🏢
IOR Number
Your IRS/EIN as Importer of Record to filter your entries.
Using a broker? They can pull this in minutes — forward this guide and ask for
ES-003 in CSV format, April 2025 to today.
1
Log into ACE Secure Data Portal
Go to
ace.cbp.gov .
Complete MFA. Confirm
you're in the Importer view — your company name should appear in the top nav.
2
Navigate to Trade → Reports
Click Trade in the top nav → Reports
→ Standard Reports → Entry Summary.
3
Find and Open ES-003
Search
ES-003. Select ES-003 — Entry
Summary (not ES-001, which is header-only). Don't click Run yet.4
Set Date Range: 04/01/2025 → Today
Entry Date From:
04/01/2025. Entry Date To: today. Enter
your IOR (IRS/EIN) in the Importer of Record field.5
Confirm These 5 Required Columns
Entry Summary Number · Entry Date ·
HTS Number - Full · Line Tariff Duty Amount ·
Line Tariff Goods Value Amount
Extra columns are fine. Missing ones cause errors.
6
Run Report → Export as CSV
Click Run Report → Export → CSV. Save
the file. Do not open in Excel first — it strips leading zeros from HTS codes.
7
Upload to the Refund Calculator
Drag-and-drop your CSV onto the calculator upload screen. Your estimate
appears in seconds. Data never leaves your browser.
05Recovery
Paths
Current Filing Routes
Three mechanisms exist to recover IEEPA duties — which applies depends on your entry's liquidation status and how much time has passed. However, given the Supreme Court’s unprecedented decision invalidating the IEEPA tariffs, the route to any potential recovery may be non-standard and will depend on further government guidance and case developments.
Route 1 — CAPE Declaration (Phase 1)
Fastest
& Cheapest
80-day
Rolling Phase 1 window
60–90 days
Refund via ACH
Low cost
Broker fee only
File a CAPE Declaration CSV via CBP's ACE portal listing all Phase 1 eligible entries. CBP reviews and issues refunds via ACH. No Form 19, no attorney required — your existing broker can handle this. CAPE went live April 20, 2026.
Identify Phase 1 entriesUse the calculator to find all entries within the rolling 80-day Phase 1 window.
→
Engage brokerProvide entry numbers, HTS codes, and duty amounts.
→
Broker files CAPE DeclarationCAPE Declaration CSV submitted via ACE portal.
→
CBP refunds via ACHApproximately 60–90 days after acceptance.
Occams Advisory and our legal and customs brokerage partners can guide you through the process.
Route 2 — CAPE Phase 2 (Pending)
Guidance Pending
TBD
Launch date — pending CBP
~37%
Of entries not yet covered
ACH
Enroll now — required for any refund
Phase 2 will cover entries liquidated more than 80 days ago — roughly 37% of total IEEPA entries. CBP has not yet published Phase 2 procedures. The action now: ensure your ACE account is active, your ACH bank account is enrolled, and your entry data is ready.
Do not wait for Phase 2 to prepare. Enroll your ACH bank account in ACE now — CBP requires this before issuing any refund. Monitor CBP.gov/CAPE and CSMS bulletins for Phase 2 launch announcements.
Route 3 — CIT Litigation
Last
Resort
Available as a backstop if CAPE Phase 1 and Phase 2 do not cover your entries, or if your CAPE Declaration is denied. Requires filing at the U.S. Court of International Trade under 28 U.S.C. §1581. Trade attorney required. Litigation can be expensive and take years. CAPE should be exhausted first.
File your CAPE Declaration now for Phase 1 entries. For Phase 2, prepare your entry data and ACH enrollment while waiting for CBP guidance. CIT is a last resort — not a replacement for CAPE.
06What to
Expect
After You File
Timeline for CAPE Declaration outcomes, Phase 2 preparation steps, and the most common reasons CBP denies claims — so you can avoid them.
CAPE Declaration Timeline
Day 1
CAPE Declaration Filed in ACE
Broker submits CAPE Declaration CSV via ACE portal. You receive a confirmation number — keep it for tracking.
Days 1–5
Automated Validation
ACE runs automated checks on the CAPE Declaration. Entries with mismatched HTS codes or amounts may be flagged for manual review.
Weeks 2–8
CBP Officer Review (if flagged)
CBP may issue a CF-28 (Request for Information). Respond promptly — delays here extend your timeline. Given CAPE filing volume, processing may take longer than normal.
~60–90 Days
Refund Issued via ACH
CBP issues refund via ACH after acceptance. Track status in ACE. Your ACH bank account must be enrolled before CBP can pay.
Phase 2 — What to Do While Waiting
Now
Enroll ACH in ACE
CBP requires an ACH bank account on file before issuing any refund. If not already enrolled, do this immediately — it takes 1–3 business days to activate.
Ongoing
Monitor CBP.gov/CAPE
CBP will announce Phase 2 procedures via CSMS bulletins. Subscribe to CBP trade alerts and check cbp.gov/CAPE regularly. Roughly 37% of entries await Phase 2 coverage.
TBD
Phase 2 Launch
Once CBP publishes Phase 2 procedures, file immediately. Have your entry data, HTS codes, and duty amounts ready to go from your ES-003 export.
Top Reasons CBP Denies Claims
Timing
Filed after the Phase 1 window closed, or entry submitted after the CAPE Declaration deadline for that entry. The most common and most preventable reason.
Wrong HTS
HTS code cited is not in CBP's published refundable IEEPA code list.
Cross-reference CSMS bulletins before filing.
Wrong IOR
Filer is not the Importer of Record on the original entry. CBP only refunds
the party that paid.
Amount Mismatch
Claimed amount doesn't match CBP records. Verify against the original
CBP-7501 form, not your internal records.
Phase Mismatch
Entry included in a CAPE Declaration but outside the Phase 1 window. CBP will reject the entire declaration if ineligible entries are included — filter carefully using your calculator output.
07Reference
Key Terms Explained
Plain English definitions for the terminology you'll encounter throughout the refund process.
ACEAutomated Commercial Environment — CBP's web portal for all trade filings, reports, and duty payments. Used to file CAPE Declarations.
CAPEConsolidated Administration and Processing of Entries — CBP's portal (launched Apr 20, 2026) for filing IEEPA refund declarations. Phase 1 and Phase 2 refunds are processed here.
CBPU.S. Customs and Border Protection — the agency that collects duties and processes refund claims.
CEECenter of Excellence and Expertise — CBP's processing centers that review CAPE Declarations and entry filings.
CHBCustoms House Broker — licensed professional who files CBP entries and CAPE Declarations on your behalf.
CITCourt of International Trade — federal court hearing trade lawsuits. Available as a backstop if CAPE is denied or Phase 2 does not cover your entries.
CSMSCBP System Messaging Service — official bulletins announcing HTS code lists, CAPE procedures, and Phase 2 guidance.
ES-003Entry Summary Report (line-level) — the ACE report containing every import line item, HTS code, and duty amount. Used to identify eligible entries.
HTS CodeHarmonized Tariff Schedule code — 10-digit number classifying goods for tariff purposes. IEEPA uses supplemental Chapter 99 codes.
IEEPAInternational Emergency Economic Powers Act — the statute used to impose the tariffs now ruled unlawful by SCOTUS (Feb 20, 2026).
IORImporter of Record — the legal entity responsible for the entry. Only the IOR can receive a duty refund.
LiquidationCBP's final accounting of duties on an entry. Typically ~314 days after entry date. Determines CAPE Phase 1 eligibility — entries liquidated within the last 80 days are Phase 1 eligible.
MFN DutyMost Favored Nation duty — the standard base tariff rate, unaffected by the SCOTUS ruling.
POAPower of Attorney — authorizes a broker to file on your behalf. Must be signed by an authorized company officer.
ProtestFormal challenge to CBP's liquidation decision, historically filed on Form 19 within 180 days under 19 U.S.C. §1514. Superseded by CAPE Declaration for IEEPA refunds.
PSCPost Summary Correction — electronic amendment to an unliquidated entry filed through ACE. Superseded by CAPE Declaration for IEEPA refunds.
TAOTrade Account Owner — primary ACE account administrator at your company, manages user access and ACH enrollment.
Ready to Get Started?
Calculate Your Refund Estimate
Upload your ES-003 CSV and see your potential recovery broken down by entry and deadline status — free, instant, and completely private.