The Small Business Tariff Refund Guide: How to Claim Your IEEPA Money Back

The $166 billion being refunded through CBP’s new CAPE portal is not just a Fortune 500 story. Roughly 330,000 U.S. importers paid IEEPA duties over the past 13 months — and a large share of them are small and mid-sized businesses that have never interacted with a federal refund program of this scale.

This guide is written for them.

Are you the kind of business this refund was designed for?

The short answer: if you are a U.S. company that was the importer of record on any shipment that paid an IEEPA Chapter 99 duty between March 2025 and February 20, 2026, yes. The Supreme Court’s ruling did not distinguish by company size.

The U.S. Chamber of Commerce, in its small-business guide, put the eligibility test plainly: You’re likely eligible if your business was the importer of record or the consignee who directly paid IEEPA tariffs.¹

That caveat — importer of record — is the part that trips up smaller operations. Many e-commerce sellers assume that because their 3PL warehouse or a fulfillment partner handled the customs paperwork, those partners are the ones entitled to the refund. They are not. Per Lizbeth Levinson of Fox Rothschild, speaking to CBS News: Only the so-called importer of record is entitled to money back.²

Check your customs entries. The importer of record is listed on CBP Form 7501. Whoever is named there is the party with the refund claim.

What small importers probably paid

The IEEPA tariffs imposed in 2025 applied across an unusually broad swath of goods. Unlike the more targeted Section 301 tariffs on Chinese imports or Section 232 duties on steel and aluminum, the IEEPA “reciprocal” tariffs covered imports from most countries and most product categories.

The e-commerce logistics firm ShipWizard summarized the exposure for online sellers: Focus on shipments hit by the now-invalidated IEEPA tariffs, which replaced the $800 de minimis exemption. These applied to low-value imports from China, Mexico, Canada, and beyond after Trump’s 2025 executive order.³

For a typical small importer, the IEEPA surcharge was a layer on top of the normal duty. If you were importing Vietnamese apparel in October 2025, for example, an illustrative breakdown from FreightFigures put the IEEPA rate at 20% on top of a 16% MFN rate.⁴ On a $2 million shipment, the IEEPA portion alone was $400,000 — all of which is now refundable.

ShipWizard’s estimate of typical refund sizes for smaller sellers: The average e-commerce seller could see $5,000–$50,000 back.³ Mid-market importers with multiple containers a month can be looking at six and seven figures.

The interest is not trivial

Here is the detail that changes the math: your refund includes statutory interest, and the clock started running the day you paid the tariff.

The U.S. Chamber of Commerce guidance states: The law requires that interest on ‘excess moneys deposited’ with CBP (overpayments) shall accrue from the date the importer of record deposits estimated duties until the date of liquidation or reliquidation… The interest rate is 6% at present.¹

For a small importer who paid $40,000 in IEEPA duties in April 2025 and gets refunded in August 2026, that is approximately 16 months of 6 percent interest — roughly an extra $3,200 on top of the principal. It is not life-changing money on a single small entry, but across a year of shipments, for a business operating on narrow margins, it is meaningful.

The four-step preparation checklist

For small businesses that want to file without outside help, the U.S. Chamber has published a four-step preparation checklist that now functions as the industry standard. Paraphrasing the Chamber guidance:¹

1. Update your CBP importer record (Form 5106) so the email on file is yours, not your broker’s.
2. Create an ACE Portal account. The Chamber notes that setup can take three to four weeks, so the real deadline to start was in March — but starting today is still better than starting in May.
3. Sign up for ACH Refund. CBP requires electronic payment for all IEEPA refunds.
4. Check for exceptions in your entry history — drawback claims, open protests, antidumping liquidation instructions, Type 08 or Type 23 entries — which are not eligible for Phase 1.

The Chamber’s sequencing point is the one most worth internalizing: CBP expects to launch its online refund system around April 20, 2026. The system will initially cover unliquidated entries and those within the 90-day reliquidation window (~63% of all eligible entries).¹ If you miss the window on the rest, the path forward gets narrower.

How to work with your customs broker

For most small importers, the customs broker is the person who will actually submit the CAPE Declaration. But brokers are not created equal, and their CAPE readiness varies widely.

The U.S. Chamber offers a short list of questions every small business should ask its broker right now, before assuming refunds are handled:

• Are you registered as an organizational broker with the authority to file CAPE Declarations?
• Do you have a process to reconcile my Chapter 99 IEEPA entries from my ACE history?
• Are you prepared to flag entries that are not Phase 1 eligible and tell me what to do about them separately?
• What is your timeline for submitting my declaration?
• What is your fee structure — flat, hourly, or percentage of refund?

The Chamber’s guidance makes clear that customs brokers provide invaluable services for small businesses engaged in international trade and will be the front line for small businesses seeking tariff refunds.¹ But the brokers themselves are currently overloaded. A significant number have paused new client intake for the duration of the Phase 1 rush.

What you cannot do (and what to stop doing)

You cannot file a refund claim for tariffs you paid on products you bought.

This is the single most common misunderstanding in consumer-facing news coverage. If you are a consumer who paid a FedEx or UPS line-item tariff charge on an imported package, you are not the importer of record. You cannot file a CAPE Declaration. Your path to any refund runs through the carrier or seller that originally paid the duty.

FedEx has stated publicly that it plans to pass through refunds: Supporting our customers as they navigate regulatory changes remains our top priority. We are working with our customers as CBP begins processing refunds and plan to begin filing claims on April 20.⁵ UPS has made similar statements. Class-action litigation against larger retailers is ongoing.

You cannot file the same entry on two declarations.

CBP’s guidance is explicit: Each entry may only be submitted on one accepted CAPE Declaration. Entries on a CAPE Declaration will receive a rejection error if they were included on a previous Declaration.⁶

You cannot amend a CAPE Declaration after it is accepted.

If you discover an error after submission, your only option is to file a new declaration with the corrected or additional entries. This is why careful pre-submission review matters more than fast filing.

You cannot use post-summary corrections as a refund mechanism.

Troutman Pepper Locke flagged this one clearly: CBP has clarified that post summary corrections (PSCs) may not be used to initiate IEEPA refund claims, making CAPE the exclusive mechanism for requesting these refunds for covered entries.⁷

The hedge fund option

An unusual side market has emerged around tariff refund claims. Because refunds can take months to arrive — particularly for smaller businesses with complicated entry histories — some hedge funds and specialty finance firms are offering to purchase refund claims outright in exchange for an immediate cash payment at a discount.

Time magazine reported the phenomenon: Some hedge funds are offering to buy businesses’ tariff refund claims. That would mean importers can get paid immediately without going through the potentially onerous process of applying for a refund, although in at least some cases it would mean selling the refunds at a discount.⁸

For a cash-strapped small business, taking a 15 to 25 percent discount to receive $40,000 in three weeks rather than $50,000 in six months may make financial sense. For a business with a strong balance sheet, it almost certainly does not. The decision depends on working capital needs and the estimated complexity of the filing.

Bennie Jackson, a small importer in the Southeast

One small-business importer whose experience surfaced in the Associated Press’s launch-day reporting was Bennie Jackson, a cigar importer. The AP reported: The company imports cigars and accessories from Nicaragua and the Dominican Republic. Last year, it paid $34,000 in tariffs and absorbed much of the cost instead of raising customer prices, Jackson said… ‘My main concern is the turnaround time. A refund process that takes several months to complete doesn’t solve the cash flow problem that it is supposed to fix.’⁵

Jackson’s concern — that a delayed refund is a partial solution — is the structural argument underneath the hedge fund market. It is also the argument Senator-level policymakers are making to accelerate CBP processing times.

Pending legislation to watch

Separately, Congress has introduced legislation that would accelerate and formalize the refund process specifically with small businesses in mind. The Tariff Refund Act of 2026 (S.3905), currently pending, would establish a 180-day statutory deadline and require CBP to coordinate small-business outreach.

The bill directs the CBP Commissioner to coordinate with the Administrator of the Small Business Administration to disseminate information to small business concerns about the payment of refunds under subsection (a), including any required documentation, actions small business concerns should take, and the expected timeline for refunds.⁹

Whether the bill passes — and on what timeline — is an open question. For now, the CAPE launch today is the operative channel.

Your to-do list this week

1. Monday, April 20: Confirm your ACE Portal account is live and ACH Refund is enrolled. If either is missing, start the process today.
2. By end of week: Pull your ES-701 and ES-702 reports from ACE. Identify every entry with a Chapter 99 IEEPA code. Separate into Phase 1 eligible / Phase 2 candidates / needs-protest-now.
3. Next week: Have a clear conversation with your broker about capacity and timeline. If they have paused new CAPE work, start shopping for an alternative.
4. Before May 1: For any entry more than 100 days past liquidation, consult counsel about filing a CBP protest before the 180-day window closes.

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Sources

1. U.S. Chamber of Commerce, “IEEPA Tariff Refunds: Guide & FAQ for Small Businesses,” and “How to Apply for Small Business Tariff Refunds,” uschamber.com, 2026.
2. CBS News, “Trump administration set to launch tariff refund portal. Here’s what to know,” April 2026.
3. ShipWizard 3PL, “Tariff Refunds FAQ: What Small Businesses Need to Know After Supreme Court’s Ruling,” 2026.
4. FreightFigures, “CBP CAPE Tool Goes Live April 20, 2026,” April 2026.
5. Associated Press (via CNBC), “Businesses can claim refunds for Trump tariffs ruled unconstitutional starting Monday,” April 19, 2026.
6. U.S. Customs and Border Protection, IEEPA Duty Refunds, cbp.gov, April 2026.
7. Troutman Pepper Locke, “CBP Issues Guidance on IEEPA Duty Refunds via New CAPE Process,” April 2026.
8. Time Magazine, “How U.S. Businesses Can Apply for Tariff Refunds,” April 17, 2026.
9. U.S. Congress, S.3905 — Tariff Refund Act of 2026, 119th Congress.