Statutory Interest on IEEPA Tariff Refunds: The Extra Money Most Importers Forget

Most conversations about IEEPA tariff refunds focus on the principal amount: the duties paid on entries covered by the Supreme Court's February 2026 ruling. That is understandable because the principal is usually the largest number on the page. But there is a second figure sitting quietly alongside every refund, one that many importers overlook entirely. That figure is statutory interest, and it accrues from the date duties were originally paid through the date CBP processes the refund.

Understanding how statutory interest works, how it is calculated, and why it matters for your total recovery is not just an accounting detail. It is a meaningful part of the business case for filing an IEEPA tariff refund claim before the 2027 deadlines.

The Legal Basis for Interest on Duty Refunds

Statutory interest on customs duty refunds is authorized under 19 U.S.C. Section 1505(c). The statute requires CBP to pay interest on any overpaid duties that are refunded following a reliquidation or a court-ordered correction. Because the IEEPA tariffs were ruled unconstitutional, entries subject to those tariffs are being reliquidated at the corrected duty rate, which triggers the interest obligation automatically.

This is not discretionary. CBP does not decide whether to pay interest on a case-by-case basis. The interest obligation attaches by law when the conditions for refund are met. That means every approved IEEPA refund claim processed through CBP's CAPE portal carries with it a statutory interest component calculated according to a published federal rate.

How the Interest Rate Is Set

The interest rate applied to customs duty refunds is tied to the Internal Revenue Service underpayment rate, which is itself based on the federal short-term rate plus three percentage points. This rate adjusts quarterly. CBP applies the rate or rates in effect during the period the overpayment was held, so if your entries span multiple quarters, a blended calculation applies.

Because the IRS underpayment rate rose sharply during the 2022 to 2024 period, many importers who paid IEEPA tariffs during that window are looking at interest rates that meaningfully add to their total refund. The longer the period between payment and refund, and the higher the rate in effect during that period, the larger the interest component becomes.

When Does Interest Start Accruing?

Interest begins accruing from the date the duties were originally paid, not from the date you file your claim. This is a critical distinction. A claim filed in January 2027 on duties paid in May 2024 will carry interest on the full period from May 2024 forward. You do not lose the interest that accrued before you initiated the refund process.

Conversely, if you wait to file and miss the deadline, you lose everything: principal and interest alike. The IEEPA refund deadlines are February 4, 2027 for fentanyl-related tariffs applied to goods from China, Mexico, and Canada, and April 5, 2027 for reciprocal tariffs applied to goods from other countries. Neither deadline extends the interest accrual period in your favor if the claim itself is filed late.

A Practical Illustration of How Interest Grows

Consider an importer who paid $500,000 in IEEPA tariffs on entries liquidated between April 2024 and October 2024. If the applicable interest rate averaged roughly 8 percent annually during the period from payment through an expected refund in mid-2027, the interest component on that $500,000 could approach $100,000 or more before the refund is issued. That is not a trivial addition.

For importers who paid IEEPA tariffs consistently across many entry summaries over a year or longer, the interest component compounds across every entry. The aggregate effect can represent a significant percentage of the total recovery, sometimes 15 to 20 percent of the principal amount depending on timing and rates.

Does Interest Apply to Section 301 Refunds Too?

The interest rules under 19 U.S.C. 1505 apply broadly to customs duty refunds issued through reliquidation. Section 301 tariff exclusion refunds have historically been processed through a different pathway and have not uniformly carried the same interest entitlement, depending on how CBP characterized each reliquidation. IEEPA tariff refunds, however, flow directly from the constitutional ruling and the resulting court-ordered relief, placing them squarely within the reliquidation framework that triggers statutory interest.

This distinction matters if you are comparing your IEEPA refund opportunity to any prior Section 301 exclusion claim you may have filed. The IEEPA refund is structured to include interest in a way that exclusion-based refunds were not always guaranteed to deliver.

How Interest Interacts With the 60 to 90 Day Payment Window

Once CBP approves an IEEPA refund claim processed through the CAPE portal, payment is issued via ACH deposit within approximately 60 to 90 days. The interest calculation runs through the date of refund processing, not the date of claim filing. That means even the 60 to 90 day processing window adds a small additional interest increment to your payment. The practical takeaway is that the sooner you file, the sooner CBP begins processing your claim, but the interest clock continues to run in your favor until the payment actually goes out.

ACH enrollment with CBP is required to receive the refund electronically. If your importer of record account is not already enrolled, that step should be completed early in the process to avoid delays at the payment stage.

Why Most Importers Have Not Yet Filed

CBP data indicates that roughly 93.5 percent of importers eligible for IEEPA tariff refunds have not yet submitted a claim, even though approximately $121.75 billion in claims have already been processed. The reasons vary: some importers are unaware the refund opportunity exists, some are unclear about the documentation requirements, and some assume the process is too complex to navigate without dedicated customs expertise.

The interest component adds an additional reason not to delay. Every month that passes without a filed claim is a month during which the interest accrual is locked in but the deadline moves closer. If you wait too long and miss the cutoff, you forfeit not just the principal but the entire interest amount that accumulated while you were deciding whether to act.

What You Need to File an Interest-Bearing IEEPA Refund Claim

Filing through the CAPE portal requires access to your ACE entry summary data, which contains the entry numbers, liquidation dates, duty amounts, and HTS classifications CBP uses to verify and calculate your refund. Your importer of record status must be confirmed, and your CBP Form 5106 information must be current and accurate. Once those elements are in place, the claim can be prepared and submitted for CBP review.

Because the interest calculation depends on accurate entry dates and duty amounts pulled from ACE, errors in the underlying documentation can affect the final payment. Working with a specialist who understands both the CAPE portal submission requirements and the interest calculation methodology reduces the risk of processing delays or partial refunds.

Check Your Eligibility With Tarisol Before the Deadline

Tarisol connects U.S. importers with the Tariff Refund Agency, a licensed specialist that files IEEPA tariff refund claims through CBP's CAPE portal on a success-based fee structure with no upfront cost. If your imports were subject to IEEPA tariffs after February 2022, there is a meaningful chance you are owed both a principal refund and statutory interest on the amounts paid.

The window to act is narrowing. Reach out to Tarisol today to confirm your eligibility, understand your estimated recovery including statutory interest, and get your claim into the queue before the February 4 or April 5, 2027 deadlines close the opportunity permanently.