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IEEPA Tariff Refunds — 2025–2026 Entries

The Supreme Court called your tariffs unlawful.
We get your money back.

If your business imported goods and paid IEEPA tariffs between February 2025 and February 2026, you are very likely owed a refund — plus interest. Our team handles the CBP filings, the deadlines, and the litigation, from evaluation to disbursement.

$166B
in IEEPA duties collected industry-wide, now subject to refund
3
refund pathways — CAPE, CBP protest, or CIT litigation
0%
upfront cost — we work on contingency
What Happened

How your tariffs became refundable

The legal path from "unlawful tariff" to "refund in your account" has moved fast. Here is the sequence that matters to your business.

FEB 2025 – FEB 2026
IEEPA tariffs are imposed and collected
The administration used the International Emergency Economic Powers Act to impose a series of tariffs on imported goods. Businesses across nearly every sector paid these duties on top of any Section 301 or Section 232 duties already owed.
FEBRUARY 20, 2026
The Supreme Court rules the tariffs unlawful
In its consolidated decision, the Court held that IEEPA does not give the President authority to impose these tariffs. That ruling did not refund a single dollar on its own — it opened the door for importers to reclaim what they paid.
MARCH 2026
The Court of International Trade orders refunds
The CIT directed Customs and Border Protection to liquidate or reliquidate entries without regard to IEEPA duties — first for unliquidated and non-final entries, then, by amended order, for entries already finally liquidated.
2026
CBP stands up the CAPE refund system
Customs built a dedicated portal — Consolidated Administration and Processing of Entries (CAPE) — to process claims in phases. Tens of billions of dollars have already been queued for refund, with a meaningful share disbursed.
JUNE 2026
The government appeals — and the picture splits in two
The Department of Justice asked the Federal Circuit to limit refunds on finally liquidated entries to importers who filed their own lawsuit at the CIT. That single argument is why timing now matters more than almost anything else on this page.
Eligibility

Three questions decide whether you qualify

Most importers who paid IEEPA tariffs during the covered period qualify for at least one refund pathway. We confirm your status at no cost.

01 — IMPORTER OF RECORD

You were the importer of record

Your business appears in Box 22 of the CBP Form 7501 on entries made between February 2025 and February 2026 — regardless of who arranged the freight or customs brokerage.

Using a broker or forwarder doesn't disqualify you. Ownership of the entry does.
02 — IEEPA DUTIES PAID

IEEPA duties were assessed

Your entry summaries show IEEPA duty line items — distinct from any Section 301 or Section 232 duties, which are not affected by this ruling and are not refundable through this process.

We separate IEEPA line items from other duties during your evaluation.
03 — A PATHWAY IS STILL OPEN

At least one refund route remains

Depending on your liquidation status, your entries fall into CAPE Phase 1, a formal CBP protest window, or the contested finally-liquidated category — each with its own clock.

Every entry runs on its own deadline. We track them individually.
Why Timing Matters Now

CBP is refunding this in three phases — and one of them may require a lawsuit

CBP's CAPE system is processing real money. But the government's position on the third phase creates a real risk for importers who sit on the sidelines.

Active now

Phase 1 — Unliquidated & recently liquidated entries

Entries not yet finally liquidated, plus those liquidated within roughly the preceding 80 days. Refunds are actively being processed and disbursed.

No CIT filing required
Launched 6/29/26

Phase 2 — Reconciliation-flagged entries

Covers entries flagged for reconciliation where the reconciliation entry has not yet been filed, under the same unliquidated/80-day test as Phase 1. This phase does not reach antidumping or countervailing duty (AD/CVD) entries — see below.

Live now
Restricted

Phase 3 — Finally liquidated entries

Under the government's current position, this phase will only pay refunds to importers who have already filed a protective lawsuit at the Court of International Trade.

Target: late July 2026
RISK

If you have not filed at the CIT and your entries are finally liquidated, the government's appeal — now pending at the Federal Circuit — could leave your refund waiting indefinitely, or excluded from Phase 3 altogether. A protective filing preserves your position without requiring you to abandon CAPE.

AD/CVD

If your entries also carry antidumping or countervailing duties, CAPE may not reach you at all. Entries suspended under an AD/CVD order can't be liquidated until that underlying case is resolved — a Commerce Department process that can run for years and sits outside CBP's control. Neither Phase 1 nor Phase 2 covers these entries, and no CAPE phase currently scheduled does either. If IEEPA duties are trapped inside an AD/CVD-suspended entry, a CIT lawsuit is likely your only near-term path to recovery.

How It Works

You don't need to learn customs law. You need a team that already has.

From first call to funds in your account, here is the sequence the team runs for every client.

01

Free evaluation

We review your import history and estimate your refund, including accrued interest, before you commit to anything.

02

Entry data collection

We work with your customs broker to pull complete entry records and flag every IEEPA-eligible line item.

03

Pathway & deadline mapping

Every entry gets sorted into CAPE Phase 1/2, a CBP protest, or a protective CIT filing — with its own clock tracked.

04

Filing & correspondence

We file through the correct channel for each entry and manage all CBP and CIT correspondence on your behalf.

05

Litigation, if needed

If a claim is denied or a pathway requires it, we pursue your refund at the Court of International Trade.

The Team Behind Your Claim

Tampa's trial firms. Dedicated trade counsel. One team.

Recovering IEEPA tariffs takes two things most firms don't have together: courtroom firepower and specialized customs expertise. This effort pairs two of Tampa's respected plaintiff trial firms — Guarnieri Trial Law and Wagner, McLaughlin & Whittemore — with Ann C. Shipherd of AC Ship Global Trade Law, a dual-licensed international trade attorney and customs broker who leads the tariff work.

Trial & litigation Guarnieri Trial Law Wagner, McLaughlin & Whittemore
× AC Ship Global Trade Law Trial advocacy and client care, paired with dedicated customs and international-trade counsel.
AC Ship Global Trade Law
Trade & Customs
Counsel

Ann C. Shipherd, Esq.

Licensed Customs Broker & International Trade Attorney · AC Ship Global Trade Law

Ann leads the trade and customs work on every tariff-refund claim. With more than 15 years in imports, exports, customs, and trade compliance — and the rare combination of a law license and a U.S. Customs Broker license — she brings the technical command of CBP procedure, entry data, and CIT litigation that this specific area demands. She has counseled importers, exporters, manufacturers, freight forwarders, and multinational corporations through the full range of customs and trade matters.

Licensed U.S. Customs Broker International Trade Attorney 15+ Years in Trade & Customs J.D., Stetson University Tampa, FL
Trial & Litigation

Guarnieri Trial Law

Tampa trial firm led by James Guarnieri, recipient of the Victor O. Wehle Trial Advocacy Award and past president of the Tampa Bay Trial Lawyers Association.

Trial & Litigation

Wagner, McLaughlin & Whittemore

One of Tampa's oldest and most respected plaintiff trial firms (est. 1967), with members of the American College of Trial Lawyers and the American Board of Trial Advocates.

What This Means For You

Specialized expertise, backed by trial power

  • 01

    Real customs-law depth on your claim

    Ann's dual license means the person handling your entry data and CBP filings does customs and trade work full-time — not as an occasional sideline.

  • 02

    Every deadline tracked, per entry

    CAPE windows, 180-day protest periods, and CIT filing deadlines run independently on every entry. The team monitors all of them.

  • 03

    Serious litigation power if CBP says no

    If a claim is denied, you have two established Tampa trial firms — with American College of Trial Lawyers and ABOTA members among them — ready to pursue it at the Court of International Trade.

  • 04

    Local relationships, national-caliber expertise

    Everyone on this team is rooted in Tampa Bay. You get specialized trade expertise without losing a responsive, local point of contact.

Fee Structure

Pure contingency. No recovery, no fee.

You don't pay to find out whether you qualify, and you don't pay to file. The team is compensated only from the refund recovered for you.

Free eligibility evaluation$0
Fee% of recovered refund
If nothing is recoveredYou owe nothing
Start Your Free Evaluation
Frequently Asked Questions

What clients ask us first

What exactly is an IEEPA tariff refund?

In February 2026, the Supreme Court held that tariffs collected under the International Emergency Economic Powers Act between February 2025 and February 2026 were imposed without legal authority. Importers who paid those duties are entitled to recover them, plus interest that has accrued since payment. Recovery is not automatic — it requires a filing through CBP's CAPE system, a formal protest, or litigation, each within its own deadline.

How do the refund deadlines actually work?

Every customs entry runs its own clock based on its liquidation date. Unliquidated entries and those liquidated within roughly the last 80 days move through CAPE now. Entries liquidated earlier but still within their protest window can pursue a formal CBP protest. Entries that are finally liquidated sit in the most contested category — currently accessible mainly to importers who have filed a lawsuit at the CIT. Missing one deadline does not necessarily close every pathway, but it does narrow your options.

Do I still qualify if I used a customs broker or freight forwarder?

Almost certainly, yes. Eligibility turns on who is listed as the importer of record on the entry — not on who physically arranged shipping or brokerage. If your company is the importer of record, you likely qualify regardless of who handled logistics.

We passed some of these costs on to our customers. Does that affect our right to a refund?

The legal right to a refund belongs to the importer of record, not to downstream customers or distributors. Passing costs along does not automatically forfeit that right, though the facts of your specific supply chain matter and we walk through them with you before you commit to anything.

Our entries also involve antidumping or countervailing duties. Does CAPE cover us?

Likely not yet, and possibly not for a while. An entry suspended under an AD/CVD order can't be liquidated until the underlying AD/CVD case is resolved by the Department of Commerce — a separate process that CBP doesn't control and that can take years. Because CAPE can only refund IEEPA duties at liquidation, neither Phase 1 nor Phase 2 reaches these entries, and there is no confirmed phase that will. If your business paid IEEPA tariffs on entries that are also tied up in an AD/CVD suspension, waiting on CAPE means waiting on that other case to close. A CIT lawsuit is generally the more direct path to recovering the IEEPA portion sooner.

Why should we file a CIT lawsuit if CAPE already exists?

Because the government has told the courts that Phase 3 of CAPE — covering finally liquidated entries — will only pay out to importers who already filed their own action at the Court of International Trade. A protective filing does not require you to abandon CAPE; the two run in parallel and protect different categories of your refund.

What does it cost to get started?

Nothing upfront. The team works on contingency, meaning the fee is a percentage of what is recovered for you, and the initial eligibility evaluation is free and confidential.

What if CBP denies our claim?

We represent you at the U.S. Court of International Trade to pursue the denied claim. Litigation is part of our standard engagement, not a separate referral.

Get Started

Find out what your business is owed

Tell us a little about your import activity. We'll confirm your eligibility and estimate your refund — free, and with no obligation.

What Happens Next

A clear picture before you decide anything

Within one business day, Ann Shipherd or a member of the team will review what you've shared and follow up to discuss your specific entries.

  • We estimate your refund, including accrued interest
  • We identify which CAPE phase, protest, or CIT deadline applies to you
  • We explain your options in plain language — no obligation to proceed
  • Everything you share is kept confidential

By submitting, you agree to be contacted about your potential claim. This does not create an attorney-client relationship.

Thank you — your request has been received. Someone from the team will follow up within one business day.
Guarnieri Trial Law IEEPA TARIFF RECOVERY

Helping Tampa Bay importers recover unlawful IEEPA tariffs through CBP filings, protests, and Court of International Trade litigation — a collaboration of Guarnieri Trial Law and Wagner, McLaughlin & Whittemore with trade counsel Ann C. Shipherd of AC Ship Global Trade Law.

Trade counsel AC Ship Global Trade Law
© 2026 Guarnieri Trial Law, LLC. All rights reserved.