Sitting on a pile of import duties you might never see again?
Tariffs. Most importers know. Over the last few years tariffs have accumulated and there is a lot of that money sitting in USCUSTOMS just waiting for people to claim it back. The reality is most companies don’t know how:
- What they are owed
- How to calculate it
- Which refund pathway applies
Ouch, that hurts! Here’s the good news: There are several methods to recover the duties you’ve paid, and a brand new CBP portal has opened recovery up to thousands of importers.
Inside this guide:
- Why Duty Refunds Matter More Than Ever
- The Difference Between Drawbacks and Tariff Refunds
- Unliquidated Entries Refund: What You Need To Know
- How To Calculate What’s Owed To You
Why Duty Refunds Matter More Than Ever
Import duties have skyrocketed.
Importers have paid astronomical sums into the coffers of our government at the border thanks to IEEPA tariffs, Section 301 China tariffs, and just about every trade remedy out there. Much of that money is refundable.
To be clear, about 330,000 importers remitted approximately $166 billion IEEPA duties covering over 53 million entries. Now there’s a lot of potential refunds heading back to importers.
But here’s the kicker…
Many importers are unaware that they even qualify. They think duties are simply a cost of doing business. They’re not. From a duty drawback program to just understanding how much tariff refund you can get from invalidated IEEPA tariffs, the unliquidated entries refund process can put big money back in your pocket.
The longer you wait, the more risk you carry of missing the window.
The Difference Between Drawbacks and Tariff Refunds
These two terms get thrown around like they mean the same thing… They don’t.
Let’s clear it up.
Duty Drawbacks
Drawback refunds customs duties paid on imported goods that are subsequently exported, destroyed, or used in the production of goods for export.
It’s not new. In fact, it’s been around for more than 200 years and is among America’s most overlooked refund programs. CBP collects duties on imports you bring into the country and refunds eligible amounts back to you through the drawback program — and you could be refunded up to 99% of the duties, taxes and fees you paid.
You qualify for drawback if:
- You imported goods and re-exported them unchanged
- You used imported materials to make products that were exported
- The merchandise was rejected, defective, or didn’t meet specs
- You destroyed the goods under CBP supervision
Each year billions of dollars go unclaimed simply because eligible companies are unaware of the program or lack the documentation necessary to file a claim.
Tariff Refunds (IEEPA-Specific)
This is the new one. And it’s a big deal.
When certain IEEPA tariffs were struck down by the Supreme Court, CBP was mandated to begin issuing refunds. CBP created a tool to manage refunds called CAPE (Consolidated Administration and Processing of Entries) on April 20, 2026.
Drawbacks pay you when you export. Tariff refunds reimburse what was illegally charged. Two distinct avenues — both route cash back to you.
Unliquidated Entries Refund: What You Need To Know
This is where it gets interesting.
When you bring merchandise into the country, your entry will go through CBP and will ultimately be “liquidated.” Liquidation is CBP’s formal acceptance that your entry is correct and that you owe that amount in duty. Until that occurs, your entry is considered to be “unliquidated.” The difference is important for purposes discussed below.
Why?
Because the new refund process treats these two types of entries very differently.
Phase 1 of CAPE Covers Unliquidated Entries
Phase One of CAPE will only accept specific unliquidated entries, as well as entries less than 80 days from liquidation. The initial batch of refunds will be distributed to importers that have open entries in CBP’s system, or entries that were recently closed.
If your entries are in this bucket, you’re in great shape. You have an easy and quick recovery path. CBP expects that approximately 63% of all entries will be Phase 1 — two-thirds of importers can proceed immediately.
Liquidated Entries Are Trickier
If your trades are already completely liquidated, then you cannot go through the normal CAPE process. You will have to:
- File a formal protest
- Wait for future phases of CAPE
- Use other administrative procedures
Time is of the essence. The sooner you know which ones are unliquidated, the quicker you can recover.
How Refunds Get Paid
Refunds processed through your accepted CAPE Declaration will be issued through ACH within 60-90 days. They are batched by importer of record, and statutory interest is applied automatically. No partial payments — you will receive a consolidated refund.
Pretty cool right?
How To Calculate What’s Owed To You
Before chasing refunds, you need to know what you’re actually owed.
Many importers neglect this step. Don’t make the same mistake. File without numbers and you won’t know if CBP agreed with your classifications. Plus you could be missing out on money!
Pull Your Entry Data
Start by logging into your ACE Portal. You need:
- Entry numbers and entry dates
- HTS codes (especially Chapter 99 codes for IEEPA)
- Total duties paid
- Liquidation status
Without this data, nothing else works.
Identify The Eligible Tariffs
You are not entitled to a refund of all duties paid. For IEEPA refunds, only duties paid on the tariffs that were invalidated. For drawback, only duties paid on merchandise that was exported or destroyed.
Assign each ticket to the appropriate refund label. Set aside what doesn’t belong.
Calculate The Refund Amount
For drawbacks, the math is fairly clean — up to 99% of eligible duties.
When requesting a refund of unliquidated entries using CAPE, CBP will recompute the duty as though the IEEPA charges were not there. The difference between what you paid and what you owe will be refunded to you.
A simplified example:
- Paid $250,000 in duties
- $90,000 was IEEPA duties
- Refund estimate = $90,000 plus statutory interest
Verify Before You File
This is the part most people get wrong.
Upload your entries with confidence. Don’t hope your data is correct. Verify HTS codes are correct. Verify duties are calculated correctly. Verify that your entry status is how you think it should be. CBP has TWO YEARS to audit entries once they refund duties. Dirty data now will create headaches later.
Bringing It All Together
Duty refunds have gone from being a little-known subject to actual cash recoveries for any importer paying significant duties. Here’s a quick review:
- Drawbacks refund up to 99% of duties on goods you exported or destroyed
- IEEPA tariff refunds recover unlawfully collected duties through CAPE
- Unliquidated entries are first in line for fast refunds
- Calculation matters — know what you’re owed before you file
- Time is critical — the longer you wait, the more your options shrink
Review your import history. Segregate unliquidated from liquidated. Begin creating a refund file. Importers who get paid first do their math the quickest.