Tariff Refunds for Small Businesses: How to Claim Yours and 4 Mistakes to Avoid
Who can claim an IEEPA tariff refund, how to prepare through CBP’s ACE and CAPE system, and the four mistakes that cost small importers money.
Only the company that actually paid the tariff, the importer of record, can claim an IEEPA refund. Claims run through U.S. Customs and Border Protection (CBP), so you need an ACE Portal account, ACH refund enrollment and your entry numbers ready. Start now, because the rules differ for entries that are still open and entries that have already been finalized.
For many small importers, a refund of tariffs paid in 2025 could mean thousands of dollars, sometimes more than a month of profit. It could also turn into a paperwork maze, a missed deadline or a scam. This guide explains who qualifies, what to prepare, the four mistakes that cost owners the most, and gives you a free readiness scorecard. For the wider cash picture, pair it with our cash flow forecast for small business.
This article is general information, not legal or tax advice. Rules and CBP systems are still changing, so confirm the latest steps on CBP.gov or with a licensed customs broker or attorney.
What happened with the IEEPA tariffs?
On February 20, 2026, the Supreme Court struck down tariffs imposed under the International Emergency Economic Powers Act (IEEPA). Those were the duties often called “reciprocal,” “baseline,” “fentanyl” or “trafficking” tariffs, plus some duties on goods from Brazil and India. The U.S. Chamber of Commerce estimates that more than 300,000 companies paid about $166 billion in these duties across more than 53 million entries, and more than 200,000 of those importers were small businesses.
Not every tariff is covered. Section 232, Section 301, Section 201, anti-dumping and countervailing duties, and regular most-favored-nation duties were not part of the ruling, so they are not part of this refund.
Dana runs a four-person online shop that imports ceramic kitchenware. In 2025 she paid about $38,000 in IEEPA duties on 41 entries, using a broker. She assumed the refund would arrive automatically. It did not. Only after she created her own ACE account, enrolled in ACH refunds and listed her entries did her claim move forward.
Who can claim a tariff refund?
Eligibility follows who paid the duty to CBP, not who ultimately bore the cost.
- Importer of record: the business whose name is on the customs entry and that paid the tariff directly.
- Consignee: the party that takes ownership of the goods after customs clearance, in some cases.
- Not eligible: a business that only paid a higher price to a supplier or distributor who imported the goods. Those costs were passed along, and CBP refunds the party that paid CBP.
If you buy from a U.S. wholesaler, you most likely cannot claim the refund yourself, though you can ask your supplier whether they plan to share any refund they receive. If you import under a broker’s account, confirm whose name sits on the entries.
Where do the refunds stand in November 2026?
CBP is running refunds through a system inside ACE called CAPE, short for Consolidated Administration and Processing of Entries. Phase one opened on April 20 and covered entries that had not yet been finalized, or were still within the 90-day window for voluntary reliquidation. Later phases opened for more entry types, including phase two on June 29, which targeted some entries flagged for reconciliation. Reports in October said more than $100 billion had already been refunded.
Finalized, or “liquidated,” entries are the hard part. On October 8, the Court of International Trade certified a class action for importers who paid IEEPA duties between February 1, 2025 and February 19, 2026. Certification does not itself order refunds, and the government is appealing, so timing for those entries could stretch into 2027. Importers with entries near their protest deadlines should not simply wait.
| Entry status | What it usually means | What to do |
|---|---|---|
| Unliquidated or within 90 days of liquidation | Eligible for the CAPE process | File through CAPE as soon as your account is ready |
| Flagged for reconciliation | Handled in a later CAPE phase | Check CBP updates and ask your broker |
| Liquidated, protest window still open | Refund rights can expire | Talk to a broker or attorney about a protest before the deadline |
| Fully finalized, window closed | Depends on court outcome | Stay in the class action or file separately, with legal advice |
How do you prepare a claim, step by step?
- Gather every entry number. Your broker can export a list, or you can pull entries from your ACE reports. Include dates, duty paid and HTS codes.
- Update your importer record (Form 5106) with a company email that is not your broker’s, so notices reach you directly.
- Create an ACE Portal account. Some importers report setup taking several weeks, so do not leave it for last.
- Enroll in ACH Refund. Refunds are paid electronically, so you need bank details on file with CBP.
- Sort entries by status: open, reconciled, drawback, in protest or already liquidated.
- Submit the claim spreadsheet through CAPE, or ask your broker to file on your behalf.
- Keep records. Save confirmations, entry summaries and proof of payment for at least five years.
CBP has acknowledged that it must pay interest on overpaid duties. The U.S. Chamber puts the current rate at 6%, accruing from the deposit date until refund, which makes early filing worth more.
Tariff Refund Readiness Scorecard
Tick what you have done. The scorecard shows your next step.
Four mistakes to avoid
1. Waiting for an automatic refund
The ruling did not send checks to everyone. Refunds follow CBP’s claim process, so a business that does nothing may receive nothing.
2. Leaving everything to your broker
Brokers are your main contact, but their email on your record means notices can go to them and not to you. Keep your own login, bank enrollment and copies of every filing.
3. Missing a protest deadline on liquidated entries
Protest windows are short. Once an entry is final, the legal path is harder. Ask your broker or attorney which entries are close to their cutoff and act on those first.
4. Falling for refund scams
Whenever money is in the news, scammers follow. Be careful with anyone who contacts you first, asks for an upfront fee, wants your bank login or promises a guaranteed payout. CBP, your registered broker and your attorney are the right channels.
They file for the duty they know about and forget the rest. Check every entry from February 2025 through February 2026, including small shipments and entries from a previous broker.
What about customers who paid higher prices?
Some sellers raised prices in 2025 to cover tariffs. A refund does not automatically require you to return that money to customers, but it can raise questions for your accounting and sometimes your contracts. Talk with a CPA about how to record the refund, whether it counts as income and how it affects your cost of goods sold for the year.
Open a separate spreadsheet called “Tariff refund tracker” with five columns: entry number, entry date, duty paid, status and claim date. It becomes your single source of truth if CBP, your broker or your accountant asks questions.
Who should act first?
- Direct importers of consumer goods, parts or materials from overseas.
- Amazon and Shopify sellers who import inventory in their own name.
- Manufacturers that bring in components under their own account.
- Owners with older entries that may be close to a protest deadline.
Risks and limits
Court cases are still unfolding and the government is appealing parts of the ruling, so timing for finalized entries is uncertain. Fees from brokers and attorneys vary. A claim can also be rejected if the entry data is wrong, which is why careful records matter. Treat every date in this article as a starting point and confirm it with CBP.
Ask your broker for a list of every entry filed under your company name since February 2025. Then check who is listed as importer of record on the first five. That single hour tells you whether you can claim and how much is at stake.
Quick action checklist
- Confirm you are the importer of record.
- Request your full entry list.
- Create your ACE Portal account.
- Enroll in ACH Refund.
- Update your importer email.
- Sort entries by status and deadline.
- Contact a broker, attorney or CPA.
- Track every filing.
Frequently asked questions
Who can get an IEEPA tariff refund?
The importer of record that paid the duties directly to CBP. Businesses that only paid higher prices to a supplier are generally not eligible.
How do I claim a tariff refund?
CBP processes refunds through its CAPE system inside ACE. You need an ACE Portal account, ACH refund enrollment and your entry details. A customs broker can file for you.
Is there a deadline to claim?
It depends on the entry status. Entries that have been liquidated have protest deadlines, so ask your broker or attorney about the dates for each entry.
Will I get interest on the refund?
CBP has said it must pay interest on overpaid duties. The U.S. Chamber of Commerce puts the current rate at 6%.
Which tariffs are not covered?
Section 232, Section 301, Section 201 and anti-dumping or countervailing duties were not part of the Supreme Court ruling.
How do I avoid refund scams?
Work only with your registered broker, a licensed attorney or CBP directly. Be wary of unsolicited offers, upfront fees and guaranteed payouts.
Final takeaways
- Only the party that paid CBP can claim the refund.
- Set up ACE and ACH first; it can take weeks.
- Treat liquidated entries with urgency.
- Never pay an upfront fee to someone who contacts you first.
While you wait on refunds, keep your cash steady with a simple break-even calculation for your next import order.
Daniel Reyes
Daniel Reyes leads the Businesstomark editorial desk, covering business news, company strategy and the tech products that shape how people work. He focuses on clear, practical explainers that help readers make smarter decisions, from choosing tools to understanding market moves.
