IEEPA Tariff Refunds: Do You Qualify, and How Much?

On February 20, 2026, the Supreme Court ruled 6–3 in V.O.S. Selections, Inc. v. United Statesthat IEEPA does not authorize the President to impose tariffs. Every IEEPA “reciprocal” and “fentanyl” tariff collected between April 2025 and February 2026 is now eligible for refund. CBP opened its refund portal (CAPE) on April 20, 2026. Roughly $166 billion was collected from over 330,000 importers — about 82% of it, ~$127 billion including statutory interest, is eligible in the first phase. If you paid an IEEPA tariff in 2025, the money is recoverable. The question is which of your entries qualify now, and which have to wait.

What’s refundable — and what is NOT

Refundable — struck down by the Supreme Court:

• IEEPA “reciprocal” tariffs (10% baseline plus country-specific rates)
• IEEPA “fentanyl / trafficking” tariffs on Canada, Mexico, and China
• These carry Chapter 99 HTS codes beginning 9903.01 or 9903.02

NOT refundable — different legal authorities, still in force:

• Section 232 (steel, aluminum 50%; autos, copper) — national security authority, untouched
• Section 301 (China, 25–100%) — separate trade authority, untouched
• Section 122 (15% surcharge on non-USMCA goods from Canada/Mexico) — a different, still-active authority

If your 2025 entries stacked IEEPA on top of Section 301, only the IEEPA layer refunds. The Section 301 duty stays owed. Getting that split right on every entry is the whole game.

Which entries qualify now

Phase 1 (open now): unliquidated entries; entries within 80 days of liquidation.

Not yet in Phase 1: older liquidated entries wait for a later phase.

Entries liquidate on a rolling basis — the window on specific entries can be closing now. Liquidation status drives priority, not the total you paid.

Estimate your exposure

Triangle’s IEEPA Refund Estimator separates the layers. Enter your product origin and import value, and it estimates the IEEPA duty that’s now recoverable versus the tariffs that remain in force — and checks whether each entry is still eligible based on its liquidation status. You walk into the refund conversation with a defensible number, not a guess.

Triangle provides analysis, not filing services or legal advice. Refund claims are filed through CBP by the Importer of Record or a licensed customs broker. Verify every entry with your broker before filing.