IEEPA Tariff Refund Documentation Checklist: What to Gather Before You File

The U.S. Supreme Court ruled IEEPA tariffs unconstitutional in February 2026, and CBP has now processed roughly $121.75 billion in refund claims. Even so, about 93.5% of eligible importers have not filed. When we talk to importers who are stuck, the reason is rarely the law. It is the paperwork. Claims slow down or get kicked back because the file is incomplete, not because the eligibility is in question.

This checklist walks through what to assemble before you touch the CAPE portal. It assumes you have already confirmed that at least one of your entries is inside a refund window: February 4, 2027 for the fentanyl-related tariffs on China, Mexico, and Canada, and April 5, 2027 for reciprocal tariffs on other countries. If you have not confirmed that yet, start there, because everything below only matters for entries that fall inside those windows.

Start With the Entry Number, Not the Invoice

Refund claims are tied to entries, not purchase orders or invoices. The entry number is the spine of your entire file. Every other document exists to support what was declared on that entry.

• Entry numbers for every shipment that paid an IEEPA tariff, ideally pulled from ACE rather than from a spreadsheet your team maintains by hand.
• Entry dates, which determine which refund deadline applies and whether the entry is inside the window at all.
• Entry summary acceptance dates, since the liquidation clock and the refund clock are not the same thing.

If you file entries through a customs broker, ask for an ACE extract organized by entry number. That single file will save you hours later and will surface entries you forgot existed.

Prove Who Paid the Duty

The refund goes to the party that paid the duty, which is usually but not always the importer of record. This is where claims most often get tangled, especially when a broker, a freight forwarder, or a foreign supplier advanced the funds.

• Importer of record number as it appears on the entry, matched against your current CBP Form 5106 record.
• Proof of payment for the duties, such as ACH debit confirmations, broker statements showing duty disbursement, or bank records showing the withdrawal.
• A written statement of who advanced the duty funds if anyone other than the importer of record paid them.

If your broker filed the entries and paid the duties out of a funded account, you will need a clear paper trail showing that the money was ultimately yours. Sort that out before filing, not after CBP asks.

Tie the Product to the Tariff That Was Collected

CBP needs to see that the entry actually paid an IEEPA tariff, at what rate, and under which order. Entries can carry several duty layers at once, including Section 301, antidumping and countervailing duties, and ordinary Column 1 rates.

• Entry summary showing the Chapter 99 subheading under which the IEEPA duty was assessed and the rate applied.
• Commercial invoice showing the declared value and a description consistent with the HTS classification.
• Country of origin documentation, which determines whether the fentanyl window or the reciprocal window applies.

Be careful here. Section 301 duties are a separate regime with separate refund rules. If your entry shows both a Section 301 rate and an IEEPA rate, isolate the IEEPA line. Mixing the two is one of the most common reasons a claim gets delayed.

Fix Data Problems Before You File

If the entry data is wrong, the claim inherits the error. Clean it up first.

• Importer of record name or number mismatches between the entry and your ACE portal profile.
• Duplicate duty payments on the same entry, which are recoverable but need to be documented as duplicates.
• Entries where goods were returned, destroyed, or re-exported, which change the refund analysis.

Pull a Trade Activity Report in ACE for the relevant period. CBP already holds this data, and reconciling it against your own records will catch errors you would otherwise discover only after filing.

Confirm Your ACH Setup

Refunds are issued by ACH, typically within 60 to 90 days of an approved claim, including statutory interest. If your ACH enrollment is stale, incomplete, or tied to a bank account you no longer use, the money can sit unclaimed.

• Active ACH enrollment in ACE linked to a current bank account.
• Correct legal entity name and address on file, matching your banking records.
• A named internal contact who monitors refund activity, so an inbound ACH does not go unrecognized.

Build One File Per Entry, Then Index It

A single master folder with everything lumped together is a recipe for a slow claim. Build one subfolder per entry number, containing the entry summary, invoice, proof of payment, origin documentation, and any correction records. Then keep a master index with entry number, date, IEEPA amount paid, and status.

For importers with hundreds of shipments, the index matters as much as the documents. It lets you file in batches, track which entries are pending, and spot entries you missed on the first pass.

Common Gaps That Stall Claims

• Duty paid by a broker or forwarder with no documentation showing the importer funded it.
• Section 301 and IEEPA amounts not separated on entries carrying both.
• Importer of record data that conflicts between the entry and the ACE profile.
• Origin documentation that does not clearly support the country used to determine which refund window applies.
• No ACH enrollment or an enrollment tied to a closed account.

Check Your Eligibility Before the Window Closes

Documentation is the part of an IEEPA tariff refund claim you control. The deadlines are fixed, and with roughly 93.5% of eligible importers still unfiled, the claims process will only get busier as February 4, 2027 and April 5, 2027 approach.

Tarisol connects importers with licensed specialists who file IEEPA tariff refund claims through CBP's CAPE portal. Fees are success based, with no upfront cost. Start by checking your eligibility with Tarisol and finding out how much of your IEEPA tariff overpayment you can recover.