Appliance importers that paid tariffs under the International Emergency Economic Powers Act are using U.S. Customs and Border Protection’s CAPE system to pursue refunds after the Supreme Court ruled that IEEPA did not authorize the president to impose the challenged tariffs.
The refund process is not a consumer rebate and it does not treat every customs entry the same way. Eligibility and procedure depend heavily on whether an entry is still unliquidated, recently liquidated, under reconciliation or already finally liquidated.
Editor’s update: This guide has been substantially revised to reflect the Supreme Court ruling, CBP’s CAPE rollout and the different treatment of newer and finally liquidated entries. For the latest refund totals and tariff developments, see Appliance News’ current tariff-refund coverage.
Why IEEPA Tariff Refunds Exist
On Feb. 20, 2026, the U.S. Supreme Court held in Learning Resources, Inc. v. Trump that IEEPA did not give the president authority to impose the tariffs at issue. The ruling sent the practical refund problem back to the trade courts and CBP.
The volume is extraordinary. A July Federal Register notice from the Department of Homeland Security said IEEPA tariffs assessed from Feb. 3, 2025, through Feb. 24, 2026, totaled an estimated $166 billion across more than 53 million entry summaries.
That scale is why CBP built the Consolidated Administration and Processing of Entries, or CAPE, inside the Automated Commercial Environment. Before CAPE, refund work was generally handled entry by entry. CAPE lets an importer of record submit many qualifying entries together and receive a consolidated refund payment.
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Who Files the Refund Request
The central party is the importer of record, or IOR — the entity legally identified on the customs entry. That may be an appliance manufacturer, distributor, retailer or another business depending on how the shipment was structured. A licensed customs broker can submit CAPE information for an importer when properly authorized.
Consumers who paid higher retail prices because tariffs increased a company’s costs do not file CAPE claims against CBP. Likewise, a retailer that bought goods domestically from a distributor generally does not become eligible merely because tariff costs were embedded in its purchase price. The customs record controls who paid the duty to the government.
CBP’s April CAPE deployment notice says only ACE account holders can file a CAPE declaration, either directly or through an authorized broker. Importers also need current account and banking information so refunds can be paid electronically.
Entry Status Determines the Refund Path
The biggest mistake for an importer is treating all IEEPA-paid entries as one refund bucket. CAPE has been deployed in phases because customs entries move through a legal process called liquidation, which finalizes CBP’s assessment of duties.
- Unliquidated and certain nonfinal entries: These were the core of CAPE’s first phase and can generally be processed without the same legal obstacle attached to older final entries.
- Reconciliation entries: Later CAPE functionality addresses certain entries flagged for reconciliation, where final customs values or other information may still be pending.
- Finally liquidated entries: These are the most legally complicated. Court orders in July created a route for importers that filed cases in the U.S. Court of International Trade, while broader relief for non-litigants has remained contested.
The Department of Homeland Security’s July 8 Federal Register notice describes CAPE as a system designed to identify eligible IEEPA lines, preserve other duties such as Section 232 or antidumping and countervailing duties, and direct the correct refund to the importer of record.
For older entries, importers should not assume that simply waiting for CAPE will preserve every right. A July 27 Holland & Knight analysis of the trade-court orders said importers that filed individual Court of International Trade actions had a confirmed path to refunds on finally liquidated entries, while non-litigants did not yet have a comparable confirmed mechanism. Companies facing that issue should obtain customs counsel rather than relying on a general news article for filing decisions.
The Records Importers Need
Refund processing is entry-specific. Importers and brokers need to be able to identify which entries actually contain IEEPA duties and separate those amounts from other tariffs, taxes and fees that remain valid.
- Importer-of-record number and ACE account access.
- Entry numbers and liquidation status.
- Harmonized Tariff Schedule classifications and the specific IEEPA duty lines paid.
- Broker authorizations and reconciliation or protest records where applicable.
- Current ACH refund banking information in ACE.
CBP says corporations and individual payees with an ACE Portal account use the portal’s ACH Refund Authorization function to enroll for electronic refunds. That matters because a successful CAPE declaration still needs a valid payment destination.
What This Means for Appliance Firms
Appliance companies can have IEEPA exposure in finished products as well as imported compressors, motors, control boards, electronics, wire harnesses and other components. But the product category alone does not establish refund eligibility. The decisive information is on the customs entry: which legal authority produced the duty, how much was paid and what the entry’s current status is.
Refunds also do not automatically translate into lower retail prices. An importer may use recovered cash to offset prior margin losses, debt, inventory costs, new tariff exposure or other operating expenses. Separate commercial contracts may also determine whether a supplier, distributor or customer has a claim to part of a recovery.
For appliance manufacturers and distributors, specificity matters. “Tariff refund” is too broad. Companies need to know whether they paid an IEEPA duty, whether they were the importer of record and whether each entry falls into a CAPE phase or a category requiring separate legal action.
Appliance News is continuing to track the refund process as CAPE phases, court orders and other tariff programs change. Our latest tariff-refund report covers the active repayment process and the separate tariff exposure importers still face.
