The IEEPA Refund Follows the Importer of Record: CAPE Phases, DDP, Couriers and What Is Left to Recover

By Bernardo Campelo, Forbes Business Council E-Commerce Leader, Amazon SPN Certified provider, Amazon SP-API authorized partner, and Founder of PrepVia.

On February 20, 2026, the Supreme Court decided Learning Resources, Inc. v. Trump, 607 U.S. 229, and held that the International Emergency Economic Powers Act does not authorize the President to impose tariffs. CBP stopped collecting the IEEPA duties on goods entered on or after 12:00 a.m. Eastern on February 24, 2026, according to CSMS # 67834313. Entries through February 23 were still subject to them.

In a Federal Register notice of October 5, 2026, CBP estimated the IEEPA tariffs assessed from February 3, 2025 to February 24, 2026 at about $166 billion, across more than 53 million entry summaries. By October 2, according to an October 8 opinion of the Court of International Trade citing a CBP declaration, about $126 billion in refunds, duties plus interest, had been certified and sent to the Treasury for disbursement.

Who gets that money is decided entry by entry: CBP pays the importer of record, or the notify party the importer designated on Form 4811. For a brand that bought DDP, shipped through an express courier or let a forwarder handle the customs side, the importer of record may not be the brand at all.

Every rule below was checked on October 26, 2026 against the CBP, Federal Register, court or statute source linked where it first appears. The refund rules change by court order as well as by CBP notice.

Who CBP Pays

CBP's IEEPA Duty Refunds page says CBP can refund IEEPA duties only to the importer of record, or to the notify party that the importer designated on CBP Form 4811, and only to a party with U.S. bank account information in its ACE Portal account. CBP's CAPE notice adds that when the designation tells CBP to send refunds to the notify party, and that party is listed on the entry, the refund for that entry goes to the notify party instead of the importer.

• Payment. With rare exceptions, refunds are paid electronically by ACH. The bank account is set up specifically for refunds and may differ from the ACH account used to pay CBP. If no refund account is on file, CBP holds the refund until one is added through the ACE Portal.
• Filing. Only the importer of record or the licensed customs broker that filed the entries can file a CAPE Declaration, and CBP says an attorney cannot file one for the importer. The declaration is a CSV file uploaded in the ACE Portal; filers cannot use the Automated Broker Interface (ABI) to file it.
• Accounts. Without an ACE Portal account there is no refund: the bank details can only be given through ACE, and whoever files the declaration also needs an ACE Portal account.

The importer of record on each entry summary, and any Form 4811 notify party listed on it, decide who CBP pays.

"The refund follows the importer of record, not the brand on the box. If your forwarder was the IOR, that is who CBP pays."

Bernardo Campelo, Founder of PrepVia

Which Entries CAPE Accepts Today

CAPE, short for Consolidated Administration and Processing of Entries, is the ACE tool CBP opened for IEEPA refunds. It has been released in phases, and the status of an entry decides whether it can go on a declaration. This is the picture as of October 26, 2026.

The 80-day line has a legal reason. CBP can reliquidate an entry on its own within 90 days of liquidation under 19 U.S.C. 1501, and the CBP page says ACE takes entries liquidated within the preceding 80 days so that CBP has time to process and reliquidate them by the 90th day.

Four more rules from the same CBP materials shape the timing and the amount:

• Timing. CBP says valid refunds generally issue 60 to 90 days after the declaration is accepted, unless a compliance concern needs review, and most reach the ACH account 3 to 5 weeks after liquidation or reliquidation. Entries that are extended, suspended or under review, and warehouse entries, keep their liquidation status, and CBP issues the refund when they liquidate.
• Interest. The refund includes interest under 19 U.S.C. 1505, in the same payment rather than as a separate one.
• Netting. CBP recalculates the whole entry, so the refund can be netted against other duties found owed at liquidation, and CBP says it is even possible to receive a bill after CAPE processing.
• No undo. Once a declaration is filed, entries cannot be removed and the declaration cannot be cancelled. If an unliquidated entry needs a Post-Summary Correction for a non-IEEPA issue, such as quantity or value, CBP says to file it before the CAPE Declaration, because no PSC is accepted once the entry is on a declaration. A PSC cannot itself request an IEEPA refund. Our guide to post-summary corrections after a receiving discrepancy covers that order.

CBP also asks importers and brokers, in CSMS # 68340863, not to put entries on a declaration if a surety paid the IEEPA duties on them, in whole or in part.

Older Liquidated Entries: Phase 3, the Class and the Clocks

For entries liquidated more than 80 days ago, the changes come from court orders, not from CBP's refund page.

Phase 3 is for plaintiffs with an entered order. In its October 8, 2026 opinion, the Court of International Trade says CBP deployed CAPE Phase 3 on October 6, 2026 for the plaintiffs in the more than 4,000 cases where the court's order has been entered. As the court understood it on October 7, declarations covering 1.1 million entries and $500 million in claimed refunds had been accepted in Phase 3. The same opinion notes that CAPE has not accepted all finally liquidated entries, nor all entries liquidated more than 80 days ago, when the importer has not filed its own lawsuit. CBP's public refund page does not describe Phase 3.

The class. The same opinion, in Freestyle World, Inc. v. U.S. Customs and Border Protection, Court No. 26-01088, certified a class of all importers of record that paid duties under the challenged IEEPA orders between February 1, 2025 and February 19, 2026, excluding any entity that has filed its own action. The court certified it under USCIT Rule 23(b)(2), where, in its words, membership is "mandatory and fixed". The order sets the case up and asks the parties for a schedule. It does not order refunds by itself. As of the October 8 opinion, the government's appeal of the part of the court's earlier refund order that covers the liquidation or reliquidation of all affected entries was pending at the Federal Circuit (No. 26-1895).

The deadlines. Under 19 U.S.C. 1514, a protest has to be filed within 180 days after liquidation or reliquidation. Under 19 U.S.C. 1504, an entry not liquidated within one year of entry is deemed liquidated at the duty the importer declared, unless liquidation was extended or suspended. A lawsuit has its own deadline: under 28 U.S.C. 2636(i), an action under the court's residual jurisdiction, 28 U.S.C. 1581(i), which is the jurisdiction the court lists for Freestyle World, must be brought within two years after the cause of action first accrues. When that clock started for a given entry is a question for trade counsel. CBP's own position is that it offers no legal guidance on whether a case needs to be filed for other entries, and an entry with an open protest is not accepted on a declaration. Whether a protest or a lawsuit makes sense for a given entry is a question for a licensed customs broker or trade counsel, and these deadlines are the reason to ask early.

The October 5 Federal Register notice is still open for comment. It is a 30-day Paperwork Reduction Act notice for the CAPE Declaration itself, the CSV worksheet, under OMB control number 1651-0149. It is not a new rule for importers, and comments are due by November 4, 2026.

DDP, Couriers and Amazon: Whose Number Is on the Entry

The importer of record is the party responsible for the customs entry, and every refund question above starts with that field. How a shipment was bought usually decides it. Our guides to who the importer of record is when a 3PL takes the container and to DDP versus DDU for a shipment to a prep center cover the background.

Some carriers publish their process. FedEx's tariff page, read on October 26, 2026, says it filed Phase 1 and Phase 2 claims as broker regardless of who was importer of record, unless the customer opted out, that for Phase 3 it files only where FedEx itself was importer of record, and that it passes refunds, with the interest CBP pays, to whoever paid the duty charges, without a fee for filing. Other couriers publish their own processes; check the current page of the courier named on your entries.

For goods imported through an Amazon logistics service, look at who is named as importer of record on the entry. We found no Amazon page for sellers that explains IEEPA refunds on imports through its logistics services as of October 26, 2026, so ask through your account channel and keep the request in writing.

The CFO Checklist

Where a Prep Center Fits

The refund is between the importer of record, its licensed customs broker and CBP. A prep center does not change who the importer of record was.

PrepVia sits at the receiving end in Miami: we receive imported freight and route it into Amazon FBA, and discrepancies are reported within 24 hours of arrival, with photos. If a container arrived short or different from its paperwork, that record is evidence for the importer and its broker, who decide whether the entry summary is wrong. If it is, and the entry is still inside the PSC window, which CBP sets at 300 days from entry or up to 15 days before scheduled liquidation, whichever is earlier, the Post-Summary Correction goes in before the entry goes on a CAPE Declaration, because CBP does not accept a PSC once the entry is on one. Our breakdown of what the customs broker, the freight forwarder and the 3PL each do shows where those hand-offs sit.

Frequently Asked Questions

Who receives an IEEPA tariff refund?

The importer of record on the entry, or the notify party the importer designated on CBP Form 4811 to receive refunds on its behalf. CBP pays by ACH, with rare exceptions, to a refund bank account registered in the ACE Portal, and it holds the refund until that account is on file.

Who can file a CAPE Declaration?

Only the importer of record or the licensed customs broker that filed the entries. CBP says an attorney cannot file a CAPE Declaration on an importer's behalf, and whoever files needs an ACE Portal account.

I bought on DDP terms. Do I get the IEEPA refund?

CBP pays whoever was importer of record on the entry, or the Form 4811 notify party listed on it. On a DDP purchase the importer of record is usually the seller or its agent, so the refund goes to them, and whether any of it comes back to you depends on your contract with them.

Can entries liquidated more than 80 days ago get an IEEPA refund through CAPE?

Only in CAPE Phase 3, as of October 26, 2026, and not for importers without their own lawsuit. The Court of International Trade says Phase 3, deployed on October 6, 2026, is open to plaintiffs in the cases where its reliquidation order has been entered. On October 8 the court also certified a class of importers that paid the challenged duties and did not sue on their own, but that order does not itself order refunds. Talk to a licensed customs broker or trade counsel about the protest and lawsuit deadlines.

Does the IEEPA refund include interest?

Yes. Interest is paid under 19 U.S.C. 1505 and arrives in the same payment as the duty refund, not separately. CBP's ES-022 report in ACE shows principal and interest as separate amounts.

How long does an IEEPA refund take?

CBP says valid refunds are generally issued 60 to 90 days after the CAPE Declaration is accepted, unless a compliance concern needs review, and most reach the bank account 3 to 5 weeks after liquidation or reliquidation. Entries that are extended, suspended or under review, and warehouse entries, are refunded when they liquidate.

Does CBP charge a fee or email updates about IEEPA refunds?

No. CBP says it charges no fee for processing tariff refunds, does not email CAPE updates, and will generally not ask for sensitive information such as bank details or passwords by email or text. If CBP asks you to verify your identity, its fraud fact sheet says to check that the request comes from an address ending in @cbp.dhs.gov or @associates.cbp.dhs.gov. CBP also says the only way to request the refund is a CAPE Declaration in ACE.

Final Take

IEEPA refunds follow the entry paperwork. A brand that was importer of record can file, or have its broker file, while its entries are inside the CAPE windows, and CBP pays the refund by ACH, to it or to the Form 4811 notify party listed on the entry, once a refund account is on file. A brand whose supplier, forwarder or courier was importer of record depends on that party's claim and on its agreement with that party. Entries outside the CAPE windows go to a licensed customs broker or trade counsel before the protest and lawsuit deadlines run out.