You Might Be Owed a Tariff Refund.
Here’s What It Takes to Collect.
The refund portal is live. Are you ready to submit a claim?
As of April 20, CBP opened CAPE, the system that pays you back for IEEPA tariffs. You have to file to get it.
The refund is the IEEPA portion only, not your total duty bill. Know the difference.
New tariff mechanisms replaced IEEPA overnight. The landscape changed. Here's what's in effect now.
The one thing most brands are missing: ACH refund enrollment. Without it, CBP holds your money.
Best Buds CX at your service. Section 122, 232, 301, and so on… We didn't name them, but we'll explain them.
What’s Changed
April 20, 2026
The refund portal is live. As of April 20, CBP launched CAPE, Consolidated Administration and Processing of Entries, inside the ACE portal. The Importer of Record or the customs broker who originally filed the entries can submit a CAPE Declaration now. CBP validates the claim, strips the IEEPA duties, reliquidates the entry, and issues repayment via ACH within 60-90 days of acceptance.
Two things to confirm before anyone files on your behalf: First, Phase 1 only covers unliquidated entries and entries within 80 days of liquidation. Know where your entries stand. Second, ACH refund enrollment is separate from ACH duty payment enrollment. If your broker files and your refund banking isn't set up correctly in ACE, CBP will accept the declaration and hold your money. That's your problem to solve, not theirs.
February 20, 2026
The Supreme Court ruled in February that IEEPA tariffs were unlawful. The refund process was ordered but unresolved — CBP had no system to process claims at scale. The window was open but there was nowhere to file. The guidance below focused on getting your documentation in order while the process caught up.
The Overturn on Tariffs
Updated April 21, 2026
On February 20, 2026, the Supreme Court ruled 6-3 that IEEPA, the International Emergency Economic Powers Act, does not give the president authority to impose tariffs. That ruling invalidated the tariff regime that hit DTC importers hard through 2025. A new executive order revoking those tariffs followed within hours.
The Court did not rule on refunds. A March 4 CIT order directed CBP to issue them. CBP said it couldn't comply. The volume was unprecedented and CBP's systems had no way to process claims at that scale. As of April 20, that's resolved. The CAPE portal is live and accepting claims.
Section 301 tariffs on specific goods are untouched by the ruling and remain in effect. A 15% global tariff under Section 122 replaced the invalidated IEEPA tariffs and runs through approximately July 24, 2026. This isn't a clean win. But the refund window is open and the claims system is live.
Get Your Paperwork and ACH In Order
Updated April 21, 2026
There is a common gap across most founder-led brands: they know they paid tariffs, but they can't prove exactly what they paid, when, on which shipment, and under which classification.
That proof lives in your Entry Summaries.
An Entry Summary is the official customs record for each shipment. It ties your import entry to a specific purchase order, itemizes the duty assessment, and gives you the exact breakdown of what was paid, to which classification, on which date. It is the document that makes a refund claim possible.
Most brands don't have these on file. Not because they weren't issued, they were, but because nobody told the founder to ask for them. Your freight forwarder has them. They do not automatically send them. More often than not, you have to request them proactively, and you should do it now before they get harder to track down.
One more thing to get ahead of: ACH refund enrollment. This is separate from ACH duty payment enrollment. If you're set up to pay duties through ACE, that does not mean you're set up to receive refunds. CBP will accept a CAPE Declaration and hold your money until valid refund banking is on file. Set this up yourself. Don't assume your broker handled it.
Pull everything related to each shipment: Entry Summary, PO, commercial invoice, bill of lading, any other documentation your vendor and freight forwarder issued. The more complete your records, the faster and cleaner your CAPE filing goes.
BEST PRACTICE: Going forward, requesting Entry Summaries should be a standard step in your import SOP. Every shipment. Filed with the PO and related shipping docs. Just make a habit of keeping it all together, build it into your SOPs.
Quick Check: When did your last shipment clear customs? Do you have the Entry Summary for it? Is your ACH refund enrollment set up?
Do You Need a Trade Attorney?
Updated April 21, 2026
CAPE is live, but that doesn't make this a DIY situation for everyone. If your 2025 tariff exposure is significant, an attorney who specializes in duty recovery is worth the conversation. They can assess whether your entries qualify, flag anything that could complicate your claim, and make sure you're not leaving money on the table through a filing error.
The portal accepts declarations from the Importer of Record directly. But attorneys are not allowed to file. Only the IOR or the customs broker who filed the original entries can submit. What an attorney gives you is the strategy and review before the declaration goes in.
Before you search, ask your network. Someone in your founder community has already found the right person. A trade attorney who has worked with DTC brands at your scale already understands the import context, the 3PL relationships, the dropship structures. That referral comes pre-vetted.
The Current Tariff Landscape
Updated May 8, 2026
Four tariff authorities are in play. Here's what each one means for a DTC importer.
Section 122: Ruled illegal on May 8, 2026, by SCOTUS. The temporary replacement for IEEPA, a flat 10% surcharge on most imports from most countries, which became effective on February 24, 2026. It was set to expire July 24, 2026, and may still be in place for certain importers. The president previoulsy announced his intent to raise it to 15% and likely plans to appeal the ruling. Refunds are in order, making most goods revert to base MFN rates averaging around 3.4%, plus whatever Section 232 and 301 tariffs apply.
Section 232: National security tariffs on specific product categories. Already in effect and untouched by the SCOTUS ruling. Current rates: steel and aluminum at 25%, copper at 50%, automobiles at 25%, semiconductors at 25%, lumber at 10%. Does not stack with Section 122, meaning that if your goods are subject to Section 232, you pay that rate, not both.
Section 301: Tariffs on Chinese goods, specifically, tied to unfair trade practice investigations. Currently 25-100% depending on product. New Section 301 investigations launched in March 2026 targeting 16 countries for manufacturing overcapacity. Those investigations typically take 12-18 months before new rates are imposed.
Section 338: A rarely invoked Depression-era authority allowing up to 50% duties on countries that discriminate against US commerce. No investigation required. Never actually used to impose tariffs, but it's on the table.
TLDR: If you're sourcing from China, you're still in the most expensive environment. If you're sourcing from Vietnam, Bangladesh, or other previously high-IEEPA-rate countries, the Section 122 window through July is the lowest cost you may see for a while. Model your landed costs for all three July scenarios: Section 122 expires, Congress extends it, or something new replaces it.
Get Ahead This Week
Updated April 21, 2026
The CAPE portal is live. Here's your sequence.
1. Confirm your ACE Portal access. Log in as the Importer of Record. If you don't have importer sub-account access, get it set up before anything else. Your broker can file on your behalf, but you need visibility into what's happening on your account.
2. Enroll in ACH refund receipt. This is separate from ACH duty payment. If you're already set up to pay duties through ACE, that is not sufficient. CBP will accept your declaration and hold your refund until valid refund banking is on file. Do this yourself. Don't assume your broker handled it.
3. Know where your entries stand. Phase 1 covers unliquidated entries and entries within 80 days of liquidation. Your broker can tell you which of your entries qualify. Ask before anyone files anything.
4. Get your Entry Summaries and know your exposure. Email your freight forwarder. Request Entry Summaries for every shipment that cleared customs in 2025. Full documents, not summary lines in a spreadsheet. IEEPA duties were assigned their own HTS Chapter 99 codes and tracked separately.
For example, here's what the entry summary for a cotton sweater from China actually looked like in 2025:
A cotton pullover sweater falls under HTS 6110.20.20 (cotton jerseys, pullovers, sweatshirts). The duty stack on the entry summary would have shown three separate Chapter 99 lines:
MFN base rate: ~16.5%
Section 301 (9903.88.xx): 7.5%, China-specific, List 4A
IEEPA (9903.01.25): 10-20%, depending on when and where in 2025 it was imported
That IEEPA amount is your refund amount. If it's significant, ask your founder network for a trade attorney referral before the CAPE declaration goes in.
The portal is live. File before the window closes on you.
At your service…
Best Buds CX is a fractional COO partnering with bold brands built on core values. We implement customer-retaining operations across the business that empower teams to operate at their highest potential so you can reclaim your time, energy, and ambition. Learn more.
