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IEEPA Professional Resources: Source Documents

TariffGuru.com provides professional-grade IEEPA tariff refund resources sourced directly from CBP official publications, Federal Register notices, and Court of International Trade filings. Every claim on this site is cited. Every statistic has a source document. Built for customs brokers, compliance officers, and trade professionals who need accurate technical information fast.

$166BRefund Pool
330K+Eligible Importers
60-90Day Payout Window
7%Annual Interest Rate

The PSC Prohibition: What Brokers Must Know

Per CBP Trade User Information Notice (Pub# 1009-1119), members of the trade community are explicitly prohibited from initiating an IEEPA duty refund request by filing a Post Summary Correction. This prohibition applies regardless of how a PSC-based service is marketed. Brokers advising clients to file PSC-based IEEPA refund requests are advising a prohibited pathway.

The only authorized IEEPA refund pathway is the CAPE Declaration submitted through the ACE Secure Data Portal CAPE tab. Brokers filing on behalf of clients must use an Importer, Organizational Broker, or Filer ACE sub-account. The Automated Broker Interface cannot be used for CAPE submissions. Filer accounts must have an active Filer Code and the first three characters of each entry number must match that Filer Code.

The government retains the right to appeal the CIT nationwide refund order. If a stay is granted, all CAPE processing could be suspended while entries continue aging toward the 80-day liquidation deadline. Brokers should advise clients to file Phase 1 eligible entries while the portal is open.
What ACE account types can submit CAPE Declarations?
Per CBP Publication No. 5514-0426, CAPE Declarations can be submitted through three ACE account types: Importer sub-accounts (IOR files directly); Organizational Broker sub-accounts (broker files on behalf of multiple clients); and Filer sub-accounts (licensed broker files using their Filer Code). For Filer and Organizational Broker accounts, the first three characters of each entry number must match the Filer Code of the submitting account. Non-importer accounts that do not meet these criteria will see the CAPE tab but receive a message that the functionality is not available.
How does the entry-level validation work?
After passing file-level validation, CBP's CAPE Mass Processing component screens each entry number individually. Validation checks include: entry number existence in ACE; IOR number match between the submitting account and the entry summary; presence of at least one IEEPA HTS Chapter 99 code on the entry; no duplicate entry numbers from prior declarations; and eligibility under Phase 1 scope criteria. Entry-level rejections display as "Rejected by batch validation" in the File Upload Status column. The Validation Result File download identifies the specific error for each rejected entry.
What is the reliquidation timeline for accepted entries?
Per CBP Publication No. 5514-0426, once a CAPE Declaration is accepted, CBP removes the applicable IEEPA HTS Chapter 99 codes from validated entry summaries and runs ACE duty-calculation checks. For unliquidated entries, CBP sets a liquidation date 45 days from CAPE Declaration acceptance. For already-liquidated entries, reliquidation occurs the next business day after CAPE processing. CAPE processing runs Monday through Thursday. Refunds are consolidated by liquidation or reliquidation date and by Importer of Record, then disbursed via ACH to the designated bank account.
How are AD/CVD entries handled in Phase 1?
Entries subject to Antidumping or Countervailing Duty orders for which the Department of Commerce has issued liquidation instructions are excluded from Phase 1 under 19 U.S.C. 1504(d). These entries are controlled by Commerce, not CBP, and the two processes cannot run simultaneously. Per the CBP Antidumping and Countervailing Duty Handbook (Pub. No. 0000-0533), suspension of liquidation applies retroactively up to 90 days before the date first ordered in cases of critical circumstances. AD/CVD entries will be addressed in a future CAPE phase with no announced timeline. Brokers should document AD/CVD case numbers, DOC determination status, and IEEPA duty components for each affected entry now.
What are the statutory interest calculation mechanics?
Statutory interest on IEEPA refunds is governed by 19 U.S.C. 1505 and 26 U.S.C. 6621. The applicable rates as confirmed in Federal Register Vol. 90 No. 186 and Federal Register Document 2026-01175: 7% annually for non-corporate filers; 6% annually for corporate filers. Interest compounds quarterly from the original entry payment date through the date CBP issues the refund. CBP calculates and includes statutory interest automatically in the ACH disbursement. The interest amount is shown separately in the ACH payment remark field alongside the principal refund amount.

Three Pillars of the IEEPA Refund Authority

Every claim TariffGuru.com makes about the IEEPA refund process is sourced to a specific publication number, statute, or court filing. Here is the complete framework.

01

The Statutory Framework

IEEPA tariff refunds are governed by three primary authorities: the Supreme Court ruling in Learning Resources, Inc. v. Trump establishing that IEEPA tariffs were imposed without statutory authority under 50 U.S.C. 1702; the CIT order in Euro-Notions Florida, Inc. v. United States directing CBP to process refunds for all eligible importers; and 19 U.S.C. 1505 and 26 U.S.C. 6621 governing statutory interest on customs duty overpayments.

02

The CAPE Administrative Process

CBP implemented the Consolidated Administration and Processing of Entries system under Publication No. 5514-0426. The system accepts CAPE Declarations as CSV files through the ACE Secure Data Portal. Filers must be the IOR or authorized broker of record for listed entries. Two validation stages apply: file-level and entry-level. Accepted declarations proceed to duty recalculation, reliquidation, and ACH disbursement within 60 to 90 days of acceptance. CAPE processing runs Monday through Thursday.

03

Phase 1 Scope and Exclusions

Phase 1 covers unliquidated entries and entries liquidated within 80 days of filing. Excluded categories under Publication No. 1009-1119: Entry Type 09 Reconciliation entries; drawback-designated entries; entries with open protests; entries subject to AD/CVD pending DOC liquidation instructions under 19 U.S.C. 1504(d); entries not filed in ACE. Interest rates per Federal Register Vol. 90 No. 186: 7% non-corporate, 6% corporate, compounded quarterly. Confirmed in Federal Register Document 2026-01175.


Source-Cited Resources for Trade Professionals

Every tool below is sourced to CBP official publications, Federal Register notices, or CIT court filings. Nothing estimated. Nothing inferred.

FREE - Reference Guide

Five Technical Pillars of IEEPA Eligibility

A concise technical reference for customs brokers and compliance officers covering the five eligibility criteria confirmed in CBP Publication No. 5514-0426 and Pub# 1009-1119.

View Technical Reference
1. Liquidation Status: Phase 1 covers unliquidated entries and entries liquidated within 80 days of filing date. Source: Pub# 1009-1119.

2. ACH Enrollment: Filer must have a U.S. bank account registered for ACH refunds in ACE. Account must be separate from any ACH account used to pay duties to CBP. Source: Publication No. 5514-0426.

3. Entry Number Format: Exactly 11 alphanumeric characters. Dashes stripped before validation. First three characters must match Filer Code for Filer/Organizational Broker accounts. Source: Publication No. 5514-0426.

4. Interest Rate Authority: 7% annually non-corporate, 6% corporate, compounded quarterly. Source: Federal Register Vol. 90 No. 186; Federal Register Document 2026-01175; 19 U.S.C. 1505; 26 U.S.C. 6621.

5. Phase 1 Exclusions: Entry Type 09, drawback entries, open protests, AD/CVD under 19 U.S.C. 1504(d), entries not in ACE. Source: Pub# 1009-1119.

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CAPE Pre-Filing Eligibility Screener

Six-question technical readiness assessment for customs brokers evaluating client eligibility. Covers liquidation status, ACH enrollment, entry type, exclusion categories, and Phase 1 vs Phase 2 routing. Instant result. No account required.

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TariffGuru's AI Recovery Agent answers technical questions with sourced responses drawn from CBP CAPE documentation, the CBP AD/CVD Handbook, Federal Register interest rates, and CIT court orders. Ask technical questions. Get sourced answers.

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FREE - Statutory Calculator

Federal Statutory Interest Calculator

Calculated per 19 U.S.C. 1505 and 26 U.S.C. 6621 using IRS quarterly overpayment rates confirmed in Federal Register Vol. 90 No. 186 and Federal Register Document 2026-01175. Compounded quarterly from original entry payment date.

Access the Statutory Interest Calculator

Federal Statutory Interest Calculator: IEEPA Tariff Refund Overpayment Rates

Statutory interest on IEEPA tariff refunds accrues from the date the original duties were paid through the date CBP issues the refund. Authority: 19 U.S.C. 1505 and 26 U.S.C. 6621.

Applicable rates as confirmed in Federal Register Vol. 90 No. 186 and Federal Register Document 2026-01175: 7% annually for non-corporate importers, 6% annually for corporate importers, compounded quarterly.

CBP calculates and includes statutory interest automatically in the ACH disbursement. The interest amount is shown separately in the ACH payment remark field alongside the principal refund amount.

Source: 19 U.S.C. 1505 · 26 U.S.C. 6621 · Federal Register Vol. 90 No. 186 · Federal Register Document 2026-01175 · Revenue Ruling 2025-22

IEEPA Refund + Statutory Interest Estimate
Principal (Duties Paid)
Statutory Interest Accrued
Total Owed to Client
Daily Accrual Rate
Quarters Elapsed

Estimate based on statutory rates per 19 U.S.C. 1505 and 26 U.S.C. 6621, compounded quarterly. Actual amounts depend on entry-level CBP data and the refund process established by the Court of International Trade.

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