TariffRefundSolutions

Answer Guide

Can I Still File for an IEEPA Tariff Refund?

Updated April 29, 2026 — for U.S. importers of record evaluating whether refund pathways are still open.

Yes. Most U.S. importers can still file for International Emergency Economic Powers Act (IEEPA) tariff refunds as of April 2026. Which deadline applies to you depends on the liquidation status of each U.S. Customs and Border Protection (CBP) entry, not on a single across-the-board deadline.

The three timing buckets

1. Unliquidated entries. CBP has not finalized duties on the entry yet. As of December 2025, roughly 19.2 million entries fell into this category. These can be corrected with a Post Summary Correction (PSC) or preserved through a Court of International Trade (CIT) filing under 28 U.S.C. § 1581. There is no protest clock yet because liquidation has not started it.

2. Recently liquidated entries (within 180 days). Once CBP liquidates an entry, the importer of record has 180 days to file a CBP protest under 19 U.S.C. § 1514. If CBP denies the protest, the denial is appealable to the CIT under 28 U.S.C. § 1581(a). This is the deadline most importers refer to as "the clock."

3. Older liquidated entries (past 180 days). The administrative protest path is generally closed, but the CIT pathway under 28 U.S.C. § 1581(i) is still available for many cases. Whether your specific entries qualify depends on facts including IOR status, the tariff actions applied, and the litigation theory.

What the Supreme Court ruling did and didn't do

On February 20, 2026, the U.S. Supreme Court held that IEEPA does not authorize the President to impose tariffs. That decision stopped new IEEPA collections and made refunds legally available, but it did not create a refund mechanism. Importers still have to affirmatively file under PSC, protest, or CIT.

CBP has announced a CAPE (Consolidated Administration and Processing of Entries) portal expected to launch in late April 2026. Even when live, CAPE only handles unliquidated entries. Liquidated entries still require protest or CIT.

If you don't know your liquidation status

Most importers don't track liquidation dates internally. Customs brokers can pull entry summaries from the Automated Commercial Environment (ACE), or Tariff Refund Solutions can pull them under Power of Attorney as part of a free eligibility review.

Free eligibility review. We pull your ACE entry data, classify each entry by liquidation status, and tell you which pathway (PSC, protest, CIT, or all three) preserves the most refund.

Start your eligibility review →