If your business has been importing goods into the United States over the past few years, you may be entitled to a refund you haven’t claimed yet. U.S. importers across multiple industries are actively recovering tariffs and duties paid under the International Emergency Economic Powers Act (IEEPA), and the window to act is open right now. The Transaction Group (TTG) and our partners may be able to help your business with tariff recovery.

Following recent court rulings that determined certain IEEPA tariffs were unlawful, U.S. Customs and Border Protection (CBP) has established formal refund procedures for qualifying importers. For many businesses, these IEEPA tariff refunds could represent a significant financial recovery. This tariff refund may be enough to meaningfully improve cash flow, reduce operational strain, and offset rising supply chain costs.

The process, however, is technical, time-sensitive, and easy to get wrong without the right guidance.

IEEPA Tariff Recovery Application

What Are IEEPA Tariff Refunds?

IEEPA tariff refunds involve the recovery of customs duties previously paid under tariffs imposed through the International Emergency Economic Powers Act. Recent court decisions determined that certain IEEPA tariffs were unlawfully imposed, triggering what has become one of the most significant customs refund efforts in recent U.S. trade history.

CBP has implemented a phased refund system through its CAPE platform within the ACE Portal to process qualifying claims electronically. According to CBP and multiple trade law sources, hundreds of thousands of U.S. importers may be affected by the IEEPA refund process.

Why Businesses Are Paying Attention

For many companies, IEEPA-related tariffs created significant additional costs over the past several years. Importers in manufacturing, distribution, consumer products, logistics, electronics, retail, and industrial sectors may have paid substantial duties that are now potentially recoverable.

Businesses are currently reviewing:

• Historical customs entries
• HTS classifications
• Importer of record status
• Liquidation dates
• Electronic filing requirements
• Refund eligibility windows

Companies that skip this review risk leaving recoverable funds permanently unclaimed.

Common Challenges With IEEPA Refund Claims

Although refund opportunities exist, the filing process is not always straightforward. Importers may encounter challenges involving:

• Incorrect importer of record information
• Missing ACH payment enrollment
• Filing errors within the CAPE system
• Incomplete customs records
• Eligibility limitations tied to liquidation timing
• Delays caused by appeals or administrative review

Recent reporting indicates that a significant number of refund claims are being rejected due to preventable filing and documentation errors, making professional guidance especially valuable.

IEEPA Tariff Recovery Application

FAQ: IEEPA Tariff Refunds for U.S. Importers

What is IEEPA?

The International Emergency Economic Powers Act (IEEPA) is a federal law that allows the President to regulate certain international economic activity after declaring a national emergency tied to foreign threats.

Who may qualify for IEEPA tariff refunds?

Generally, importers of record that paid qualifying IEEPA-related duties may be eligible to pursue refunds through CBP’s CAPE refund process. Eligibility may depend on entry timing, liquidation status, and whether the tariffs fall within currently approved refund phases.

How do importers request IEEPA tariff refunds?

Refund requests are processed electronically through CBP’s ACE Secure Data Portal using the CAPE system. Importers or authorized customs brokers must submit refund declarations electronically.

Can customs brokers submit claims on behalf of importers?

Yes. Authorized customs brokers may assist businesses with preparing and submitting IEEPA tariff refund filings through the ACE/CAPE platform.

Are all IEEPA tariffs refundable?

No. Refund eligibility may vary depending on the tariff authority used, the timing of liquidation, and the specific HTS codes involved. Some tariffs imposed under different legal authorities may not qualify for refunds.

How long does the refund process take?

According to CBP guidance referenced by multiple trade law sources, approved refunds may generally be issued within approximately 60 to 90 days following acceptance of a validated claim, although some claims may require additional review.

Are refunds paid electronically?

Yes. CBP currently requires approved IEEPA tariff refunds to be distributed electronically through ACH payment systems.

What is the CAPE system?

CAPE stands for Consolidated Administration and Processing of Entries — CBP’s refund processing framework within the ACE portal used to manage IEEPA tariff refund claims at scale.

Why are some IEEPA refund claims being rejected?

Common rejection issues include filing errors, missing documentation, importer mismatches, incomplete payment information, and eligibility timing problems.

Can small businesses qualify for IEEPA tariff refunds?

Yes. Small businesses, distributors, manufacturers, retailers, and importers of many sizes may potentially qualify if they paid eligible IEEPA-related duties.

What other financial recovery programs should businesses review?

Many businesses pursuing IEEPA tariff refunds are also exploring IRS penalty recovery opportunities under the Kwong v. United States ruling. This was a landmark federal court decision that may have extended IRS filing deadlines for many businesses from January 2020 through July 2023. Additional programs worth reviewing include R&D tax credits, cost segregation studies, and other business incentive programs that may improve cash flow and reduce tax exposure. [Learn more about Kwong and additional recovery opportunities here.]

Ready to Find Out What You’re Owed?

Navigating IEEPA tariff refund claims alone can be costly and time-consuming. And, a single filing error can mean the difference between a successful recovery and a rejected claim. That’s where The Transaction Group comes in.

About The Transaction Group

Established in 2004, The Transaction Group (TTG) provides business services and payment processing solutions for companies across a wide range of industries throughout the United States and internationally. While TTG is widely recognized for its expertise in merchant account services and high-risk payment processing, our broader focus is helping businesses identify financial and operational opportunities that support long-term growth.

From IEEPA tariff refunds for U.S. importers and IRS penalty recovery assistance to R&D tax credits, cost segregation studies, and specialized financial services, TTG works with businesses to uncover opportunities that improve cash flow and strengthen overall financial performance.

If your business believes it may qualify for IEEPA tariff refunds or other financial recovery programs, contact The Transaction Group today to learn more about available recovery opportunities and customized business solutions.

IEEPA Tariff Recovery Application