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 four 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 filed through the CAPE portal (Phase 1, live since April 20, 2026) or corrected with a Post Summary Correction (PSC), and should also be 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 80–90 days). Entries liquidated inside CBP's voluntary reliquidation window are also CAPE Phase 1 eligible. They can additionally be protested under 19 U.S.C. § 1514. The CAPE path is generally faster (60–90 day processing after an accepted Declaration) when it works.
3. Liquidated entries (within 180 days, outside CAPE window). Once outside the 80–90 day reliquidation window, the protest path is the administrative option. The importer of record has 180 days from liquidation to file under 19 U.S.C. § 1514. If CBP denies, 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."
4. 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 CAPE, PSC, protest, or CIT.
CBP's CAPE (Consolidated Administration and Processing of Entries) portal launched on April 20, 2026. Phase 1 handles unliquidated entries and entries liquidated within the past 80–90 days. Entries finally liquidated outside that window still require protest or CIT. A Federal Circuit appeal is pending, with a decision expected early June 2026, that could pause CAPE entirely, which is why CIT filing in parallel matters.
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 (CAPE, PSC, protest, CIT, or all four) preserves the most refund.
Start your eligibility review →