IEEPA Tariff Refunds

The International Emergency Economic Powers Act (IEEPA) was invoked by the Trump administration beginning in 2025 to impose broad tariffs on virtually all U.S. trading partners. These tariffs were struck down by the Supreme Court on February 20, and billion have been refunded to importers.

If you paid IEEPA tariffs on imports during the period between February 2025 and February 2026, you may be entitled to a refund. One the first steps in this process will be to establish an ACE account.

History of the IEEPA Tariffs

Below is a proposed chronology and summary of the IEEPA tariff measures and related developments.

Background. Beginning in 2025, the administration invoked the International Emergency Economic Powers Act to impose broad tariff measures tied to border security, fentanyl trafficking, and reciprocal trade deficit policies.

Canada / Northern Border. Additional duties were imposed on covered Canadian goods, including a general rate on many goods, a separate rate for energy and energy resources, and a higher anti-transshipment rate for certain non-USMCA-origin merchandise determined to have been routed through Canada.

Mexico / Southern Border. Additional duties were imposed on many products of Mexico, with carve-outs and exceptions for some USMCA-qualifying goods, certain potash, and accompanied personal-use baggage.

China / Fentanyl Supply Chain. Additional IEEPA duties were imposed on broad ranges of Chinese and Hong Kong products based on the synthetic opioid and fentanyl supply chain rationale, and related fentanyl measures also applied to some Canadian and Mexican goods.

Reciprocal Tariffs. A baseline additional duty was imposed on most products of any country, with separate country-specific reciprocal rates implemented through additional Chapter 99 provisions.

Litigation and Refunds. The attached material also summarizes the later refund and litigation environment, including the Supreme Court decision, CIT proceedings, and CBP refund processing developments.

IEEPA “type” / program	Representative CH 99 range / examples	Primary purpose / legal basis
Northern border / illicit drugs (Canada)	9903.01.10–9903.01.16	Additional duties on covered products of Canada under EO 14193, including differing rates for most goods, energy/energy resources, and certain transshipment cases.
Southern border measures (Mexico)	9903.01.01–9903.01.05	Additional duties under EO 14194, generally on products of Mexico, with exceptions for certain USMCA and related categories.
Fentanyl / synthetic opioid supply chain	9903.01.20, 9903.01.24, and related 9903.01.xx provisions	Additional duties targeting the PRC synthetic opioid / fentanyl supply chain and related goods.
Reciprocal trade deficit tariffs	9903.01.25; 9903.02.02–9903.02.71	Baseline and country-specific reciprocal tariff measures implemented through Chapter 99.

Selected developments.

March 4, 2026: CIT orders nationwide removal of IEEPA duties on non-final entries.
March 6, 2026: CBP says it needs 45 days to process IEEPA tariff refunds.
March 13, 2026: CBP reported to be building the CAPE system to process refunds at scale.
March 20, 2026: CIT expands the refund order to include Brazil and India tariffs.
April 10, 2026: reporting on CAPE system launch for consolidated refunds.
June 2, 2026: DOJ notifies the court it will appeal the universal refund order.
July 13, 2026: nearly 2 million reconciliation entries reportedly covered by CAPE.
July 15, 2026: CIT confirms CAPE Phase 3 refunds across 3,700 cases.

  
    Summary of IEEPA Provisions

          IEEPA “type” / program
          Representative CH 99 range / examples
          Primary purpose / legal basis
        
          Northern border / illicit drugs (Canada)
          9903.01.10–9903.01.16 (e.g., 9903.01.10, 9903.01.13, 9903.01.16)
          Additional duties on covered products of Canada under EO 14193 (Northern Border / Illicit Drugs), including +25% (later +35%) on most Canadian goods (9903.01.10), 10% on Canadian energy/energy resources (9903.01.13), and +40% transshipment-evasion duty (9903.01.16) for non-USMCA-origin goods CBP determines were transshipped via Canada.
        
          Southern border measures (Mexico)
          9903.01.01–9903.01.05 (e.g., 9903.01.01, 9903.01.02, 9903.01.03)
          Additional duties under EO 14194 (Southern Border Measures): generally +25% ad valorem on most products of Mexico (9903.01.01), with carve-outs/exceptions in 9903.01.04–.05 for USMCA-qualifying goods, certain potash, and personal-use accompanied baggage.
        
          Fentanyl / synthetic opioid supply chain (China, Canada, Mexico)
          9903.01.20 (initial), later 9903.01.24 and associated fentanyl codes for China/Hong Kong; parallel fentanyl-related codes for Canada/Mexico within 9903.01.xx
          Tariffs under EO 14195 targeting the PRC synthetic opioid/fentanyl supply chain: additional ad valorem duties, generally 10–20% with later rate changes reflected in CBP guidance, on broad ranges of Chinese and Hong Kong products, plus fentanyl-related IEEPA duties on certain Canadian and Mexican goods, sometimes layered on top of Sections 301 and 232 duties.
        
          Reciprocal trade deficit tariffs (global baseline + country-specific)
          9903.01.25 (baseline “any country”) and 9903.02.02–9903.02.71 (country/region-specific reciprocal codes)
          “Reciprocal” tariffs under EO 14257: 9903.01.25 imposed an additional 10% duty on most products of “any country,” subject to numerous exceptions, while the 9903.02.xx series implemented country-specific reciprocal rates.