Frequently Asked Questions

Yes. On February 20, 2026, the Supreme Court ruled in Learning Resources v. Trump that IEEPA does not authorize the president to impose tariffs. On March 4, the Court of International Trade issued a Universal Refund Order directing CBP to process refunds for all importers of record. Two days later, on March 6, the CIT amended that order — staying its immediate enforcement while CBP builds CAPE, a new system to handle refunds at scale. The March 6 order did not nullify the refund obligation; it suspended the enforcement mechanics while CBP develops the infrastructure to comply.

CBP launched Phase 1 of CAPE — the Consolidated Administration and Processing of Entries portal — on April 20, 2026. Phase 1 covers approximately 63% of affected entries; later phases will address the rest.

The ruling covers all tariffs imposed under IEEPA, paid between February 4, 2025 (when the "fentanyl tariffs" on Canada, Mexico, and China took effect) through February 24, 2026 (when IEEPA duties were stopped). This includes the April 2025 reciprocal tariffs on most trading partners, as well as IEEPA tariffs on Venezuela, Brazil, and Russia.

Section 301 China tariffs, Section 232 steel and aluminum duties, and AD/CVD duties are not covered — they remain in place under separate legal authority. The 10% Section 122 replacement tariff currently in effect is also not subject to refund.

Per CBP's own court filings, over 333,000 importers paid approximately $166 billion in IEEPA duties across 53 million individual entries. With accrued interest, total refunds could exceed $175 billion.

Your specific recovery depends on your import volume, countries of origin, the HTS codes involved, and the IEEPA rates applied to each entry. A TRG audit quantifies your exact amount — itemized by entry — before you commit to anything.

Yes. CBP has acknowledged the obligation to pay interest alongside IEEPA refunds. Under 19 U.S.C. § 1505(b), interest accrues on customs overpayments at the rate set quarterly under IRC § 6621, compounding daily under § 6622.

CAPE stands for Consolidated Administration and Processing of Entries — CBP's new portal inside ACE for processing IEEPA refunds at scale. Phase 1 launched on April 20, 2026 and covers approximately 63% of affected entries: unliquidated entries and entries liquidated within the prior 80 days (the voluntary reliquidation window).

Excluded from Phase 1 — and deferred to later phases or alternative remedies — are entries that have already finally liquidated, entries with active protests, entries flagged for reconciliation, entries with drawback claims, and AD/CVD-suspended entries. CBP has not announced a Phase 2 launch date.

Technically, yes. But the ACE portal is dense and navigating customs data — entry summaries, liquidation status, HTS codes, IOR records across multiple brokers — is a complicated process most business owners haven't done before.

TRG handles the entire process. You recover what you're owed.

Yes — for Phase 1 entries, refunds do not happen automatically. A CAPE Declaration must be submitted.

For entries near the 80-day liquidation cutoff that may not make it into a CAPE Declaration in time, a protective protest under 19 U.S.C. § 1514 preserves your refund right while CAPE eligibility is confirmed. Entries beyond the 80-day window (but still within the 180-day protest period) currently sit outside Phase 1. Finally-liquidated entries beyond the protest window are deferred to Phase 2 or potentially CIT litigation.

TRG audits your full entry portfolio, identifies which entries fit Phase 1, flags entries near deadlines, and coordinates the filings.

Under 19 U.S.C. § 1514(a), importers have 180 days from the date an entry is liquidated to file a formal protest with CBP. After that window closes, the entry becomes "final." Recovery on finally-liquidated entries may require CIT litigation, and that remains an open legal question.

Most IEEPA entries are still either unliquidated or within the protest window, but entries from early-to-mid 2025 are actively liquidating. If you haven't audited your entry status recently, some of your entries may be closer to that threshold than you think.

CBP says 45 days to process and 60–90 days for payment after CAPE Declaration acceptance. However, the DOJ can appeal until early June 2026, which could delay this significantly.

For importers who need working capital now, TRG's claim purchase converts your pending refund into immediate cash — see below.

Possibly — but coverage varies significantly. Many freight forwarders and customs brokers have filed protests for active clients, but not necessarily for all entries, all time periods, or all IOR numbers you may have used.

We recommend verifying with your broker which specific entries were covered and cross-checking against your full import history. TRG can audit your entry data to identify gaps even if your forwarder has handled part of the process.

TRG operates two core services:

• Managed Recovery — We audit your import history, track entry status and protest windows, monitor CAPE and litigation developments as they unfold, and manage the refund process on your behalf.
• Claim Purchase — For importers who need cash now, we purchase your anticipated refund claim and pay you upfront — typically within days. You get immediate liquidity without waiting for CBP.

Both services start with a free consultation so you know your eligibility before deciding how to proceed.

No. Tariff Recovery Group is a specialty finance and consulting firm, not a law firm or customs broker. We do not provide legal advice. For entries requiring CIT litigation or formal legal counsel, we coordinate with licensed customs attorneys.

We review your import history from February 2025 forward and deliver:

• Entry-by-entry identification of IEEPA-affected entries
• Total estimated refund amount
• Liquidation status and protest window for each entry
• Flag of any entries approaching the 180-day threshold
• Recommended protective steps given your specific portfolio