IEEPA REFUND ELIGIBILITY · 3-MINUTE SCREEN

Did you pay IEEPA tariffs? Find out if your entries are recoverable.

The February 20, 2026 Supreme Court ruling in Learning Resources v. Trump struck IEEPA tariff authority, invalidating roughly $166 billion in IEEPA duties collected across 53 million entries. CBP's CAPE refund process went live April 20, 2026. The legal posture favors recovery, but the procedural windows close fast and a DOJ appeal on whether refunds extend beyond named plaintiffs is pending at the Federal Circuit. Mid-2025 entries face the window first.

This three-minute screen identifies whether your import operation has IEEPA refund-eligible entries, estimates the recovery magnitude, and produces a memo with the questions to put in front of your customs broker, trade counsel, and CFO.

The screen is calibrated to the conditions that determine eligibility: entry dates within the IEEPA tariff period (through February 23, 2026), duty paid under IEEPA authority specifically (not Section 232 metals or pharma, not Section 301 China, not Section 122, not AD/CVD), and liquidation status (CAPE Phase 1 covers unliquidated entries and those within 80 days of liquidation; older liquidated entries require a protest within 180 days).

Output is preliminary and informational. Filing decisions require validation by qualified customs counsel and a licensed customs broker.

6 QUESTIONS · OUTPUT UPDATES LIVE

Where do your entries sit on the eligibility map?

Six questions calibrated to the eligibility conditions. Honest "don't know" answers are common and the screen accommodates them. The output panel updates as you answer.

01. Imports
02. Authority
03. Magnitude
04. Timing
IMPORTS · Q1
Did you import goods into the US between January and August 2025?
AUTHORITY · Q2
Of those entries, did any include duties paid under IEEPA reciprocal tariff authority specifically (the across-the-board reciprocal tariffs, not Section 232, 301, or AD/CVD)?
MAGNITUDE · Q3
Approximate US import value during that period?
TIMING · Q4
What's the liquidation status of those entries?
DOCUMENTS · Q5
How accessible are your entry summaries and tariff classification records?
STAKEHOLDERS · Q6
Who's been in the conversation about IEEPA refunds internally?
ELIGIBILITY READ · LIVE
Awaiting answers
Eligibility verdict updates as you answer
Sample
IEEPA Eligibility Memo · 1 page
Apex Industrial Holdings · Eligibility read
IEEPA refund check · May 2026 · Prepared for: CFO
Verdict
EligibilityLikely eligible
Recovery range$1.4M – $3.2M
First window closes~60 days
Documentation readinessHigh · Direct ACE access
Top 3 priorities
01Pull entry summaries for IEEPA-paid entries dated April–August 2025; reconcile against ACE
02File protective Post-Summary Corrections on unliquidated entries; protest liquidated entries within the 180-day window
03Engage qualified customs counsel to validate filing posture given pending Federal Circuit appeal
Broker question set 8 questions
01What is our IEEPA-paid duty total for entries dated April–August 2025?
02How many entries from that period are still unliquidated, how many are within 80 days of liquidation, and how many are within the 180-day protest window?
03What's the broker's CAPE Phase 1 throughput capacity given current backlog?
Sample output · Actual memo personalized to your inputs
REQUEST · MEMO
Get the eligibility memo
One-page eligibility memo · Arrives within 2 business days · Optional 30-minute pressure-test call

By submitting, you agree that Tariff Terrain may use your responses to generate the memo and may follow up about your IEEPA refund posture. The screen is informational and not a substitute for legal, tax, or customs advice. Filing decisions require validation by qualified customs counsel and a licensed customs broker.

What the memo covers

The eligibility memo is calibrated to your specific inputs. It is delivered as a one-page document with prioritized action paths, a recovery magnitude range, a window countdown, and the questions to put in front of your broker, counsel, and CFO.

SECTION 01
Eligibility verdict and reasoning
Likely / possibly / unclear / not eligible, with the specific conditions that drove the verdict and what's missing if the read is uncertain.
SECTION 02
Recovery magnitude estimate
Range based on import value and IEEPA-share assumptions. Conservative and aggressive bounds, plus the specific assumptions you would validate with your broker.
SECTION 03
Window timing
Days until your earliest recovery window closes (CAPE Phase 1 at 80 days, protest at 180 days), given typical liquidation timing for entries in your stated period.
SECTION 04
Three concrete next steps
Document checklist for your broker, the questions to put in front of trade counsel, and the internal stakeholders whose alignment determines whether you actually file.
How the screen works
Three eligibility conditions. Entry date within the IEEPA period (through February 23, 2026), duty paid under IEEPA authority specifically, and liquidation status (CAPE Phase 1: unliquidated or within 80 days of liquidation; otherwise protest within 180 days).
Court posture. The February 20, 2026 Supreme Court ruling striking IEEPA tariff authority is foundational. A DOJ appeal on whether refunds extend beyond named plaintiffs is pending at the Federal Circuit; CAPE refund processing continues in the interim.
Procedural path. CBP's CAPE Phase 1 handles unliquidated entries and recently liquidated entries. Phase 2 (additional liquidated entries) is in development. Older entries may require alternative paths.
Magnitude estimation. Recovery range derives from your stated import value and a plausible IEEPA-share assumption (typically 4-10% of total import value, depending on country mix and entry timing).
Eligibility conditions tested3
Diagnostic questions6
Output format1-page memo
Turnaround2 business days