IEPPA tariff refunds

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Your partner for IEEPA refund recovery

Successfully helping importers get the IEEPA refunds they’re due.

Published on 8 July, 2026

When complex regulatory challenges arise, the right expertise can transform obstacles into opportunities.

The International Emergency Economic Powers Act (IEEPA) refund mechanism presents a valuable opportunity for US importers to recover duties, tariffs, and interest. However, evolving regulations, strict deadlines, and complex filing requirements can make the process challenging.

Since this change in policy, Kuehne+Nagel has been successfully helping companies with recovering duties and interests they are due.

Key challenges

Tight timelines and eligibility windows

IEEPA refund eligibility is closely tied to strict timelines. Certain entries only qualify within defined post liquidation windows, making early action essential to avoid losing recovery rights.

Complex and sensitive filing requirements

While digital tools such as the Consolidated Administration of Processing of Entries (CAPE) provide a structured pathway to submit claims, the process remains detail driven, requiring accurate declarations and careful validation to ensure successful submission.

Evolving legal and regulatory landscape

Ongoing litigation and phased implementation of refund mechanisms mean that eligibility, timelines, and processes may continue to change, requiring close monitoring and expert guidance.

Significant data and documentation requirements

Each refund claim must be supported by precise entry level data, requiring importers to identify affected shipments, validate duty payments, and consolidate supporting documentation across their records.

The catalyst – a landmark Supreme Court decision

The path to these refunds began with a pivotal Supreme Court decision that challenged existing tariff structures and questioned their legality.

Announced on 10 April 2025 by the US Customs and Border Protection (CBP), the ruling established a formal refund mechanism that allows companies to seek restitution for overpaid duties.

To claim refunds, importers must use the CAPE tool, the first phase of which has been launched in the Automated Commercial Environment Secure Data Portal (ACE). While the process is complex, it offers a significant financial lifeline for eligible importers.

For additional context on this mechanism, read our article here.

Supreme Court Washington DC USA

Significant recoverable refunds are at stake — timing and accuracy determine success.

How Kuehne+Nagel simplifies the complexity

Navigating the ACE portal and submitting CAPE declarations requires more than just raw data – it demands know-how and strategy.

Kuehne+Nagel supports importers by structuring numbers while safeguarding your rights.

Analyzing financial data

Our billable analytical services include:

Entry population and segmentation

We identify impacted entries and bucket them by liquidation status and deadlines.

Liquidation monitoring

We set up alerts and provide periodic reporting so you never miss a critical deadline.

Protest preparation

Where appropriate, our team prepares entry lists, assembles supporting documentation, and submits timely filings for liquidated entries to preserve your rights.

Refund readiness documentation

We create a consolidated refund record for immediate submission when formal processes are announced.

ACE portal support

We assist with applications, configuration, training and custom report generation in the portal.

Refund estimates

We generate estimates to give you a clear snapshot of your expected recovery.

Man working at the table

Proactive recommendations for pursuing IEEPA refunds

Now that the legislation has changed, there are a series of actionable steps you can take to ensure your data is accurate and eligible:

  • Master your data:  Gain a thorough understanding of your ACE reports to fully analyse your footprint as an importer.

  • Partner with experts:  Work with a knowledgeable subject matter expert or broker to ensure your eligibility is airtight.

  • Automate your recovery:  Set up Automated Clearing House (ACH) payments for immediate electronic refunds upon approval.

  • Prepare for the future:  Use this process to ensure the accuracy of all your import data, preparing you for the next shift in US trade administration focus.

IEEPA refunds require timely action —
don't let owed capital slip through your fingers.

IEPPA tariff refunds

Ready to claim your IEEPA refunds?

Our local teams have the expertise and proven track record to help you overcome regulatory hurdles, ensuring you get access to the refunds your business is owed.

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Greg Tompse

Author: Greg Tompsett

Greg Tompsett brings over two decades of expertise in international trade compliance, customs operations, and supply chain optimisation. As Senior Vice President, US Customs at Kuehne + Nagel, Greg leads strategic initiatives that streamline cross-border logistics and ensure regulatory excellence across complex global networks. Known for his pragmatic leadership and deep industry insight, Greg has been instrumental in shaping customs strategies that align with evolving trade policies and digital transformation.