Your IEEPA Refunds, Done Right
The IEEPA Tariffs are ending as abruptly as they started. But like everything for the past 18 months there is still work to do.
CBP isn’t likely just issue your refund. They rerun your entire duty calculation. If your data isn’t clean, you could receive a bill instead of a refund.
How KlearNow
Helps You Get IEEPA Refunds Right
Critical sequencing risk: When CBP processes your CAPE Declaration, they will rerun their own tariff stacking and duty calculations. If you paid the flat IEEPA duty, CBP may deduct the normal duty rate from your refund. If Section 232 was not declared correctly, you could be leaving money on the table or even be at risk of receiving a sumplimental bill.
The importers who recover the most from CAPE are not necessarily the ones who file fastest: They are the ones who have a handle on their data.
If Sec 232 refunds or filing errors are identified for unliquidated entries, filing post-summary corrections prior to the CAPE Declaration is important to maximize reliable refund estimates and avoid compliance surprises.
The three-step sequence that protects your refund and your data:
Step 01: Know Your Data
Identify tariff stacking issues and data gaps before they become problems.
Using ACE reports (ES-003, ES-701, ES-010) so you see what CBP sees, each entry line for a shipment that paid IEEPA is reviewed for:
- Tariff stacking hierarchy: Section 232, Section 301 (China), IEEPA, and fixed reciprocal tariffs potentially overriding other duties on the same line
- Missing or incorrect CH99s based on dates and country declarations
- Entry not eligible for Phase 1 CAPE Declarations: recon, drawback, etc.
Entries approaching and/or past the 80-day post-liquidation window for CAPE Phase 1 eligibility
Step 02: Housekeeping Diligence
Identify and amend any Sec 232 splits, errors, and other opportunities before CAPE upload.
Before your entries liquidate through CAPE, our team reviews them for Section 232 refund and other opportunities recoverable through a Post Summary Correction:
- Once an entry liquidates through CAPE, the PSC window closes. You cannot file a PSC on a liquidated entry only a Protest.
- PSCs filed before liquidation demonstrate reasonable care and reduce enforcement risk.
- The CAPE process will recalculate duties after removing the current IEEPA on file and no IEEPA would have been paid on Sec 232 value
Skipping this step, 232 refund opportunities from splitting non-metal content value could become moot without reallocating to IEEPA first.
Step 03: Submit CAPE Declaration
Submit your CAPE Declaration after Completing Steps 1 and 2
Once your data is reviewed and any material corrections are completed, our team will guide you through the submission of your CAPE Declaration through CBP’s ACE portal.
- CSV upload prepared with all entry numbers in CBPs required format
- Legal acknowledgment checkbox, certifying compliance with all applicable laws including who is authorized to submit the request.
- Confirm CAPE declaration acceptance and how to monitor claim and refund processing status
- Manage CBP requests for additional information as applicable
KlearNow supports you through the portal, monitoring, and CBP responses.
What’s Changed: CAPE Filing Update May 2026
CBP has issued several updates since CAPE Phase 1 launched on April 20. Here’s where things stand:
- $35.46 billion in estimated IEEPA duty refunds and interest have been calculated for liquidated and reliquidated entries
- 15.1 million entries have passed CAPE file and entry-level validations and been accepted for IEEPA duty removal
- 8.3 million entries have been liquidated or reliquidated with IEEPA duties removed
- ACH refund payments began issuing as of May 12, 2026
- On May 15, CBP issued a Trade Bulletin with additional CAPE filing resources and guidance for importers and brokers
Common issues flagged by filers so far: HTS relationship/sequence mismatches, ACE access problems (password resets, username errors), and confusion over which IOR is authorized to submit a CAPE Declaration. If any of these apply to your entries, contact us before resubmitting — a rejected Declaration can complicate your timeline.
Phase 1 is still active. If you haven’t filed yet, the window for unliquidated entries and entries within 80 days of liquidation is open. Entries approaching that 80-day threshold should be prioritized now.
Why KlearNow
ACH enrollment verified
CBP no longer issues paper checks. We confirm all IOR numbers are enrolled before submission, because an unverified ACH is a rejected refund.
Scale brokers can’t match
Retroactive auditing across thousands of historical entries requires a different capability than day-to-day filing. We process in days what takes a manual team weeks.
Transparent pricing
Simple per-entry pricing. No hidden fees, no minimum volume, no surprise invoices. Discount available for SaaS commitment.
One consolidated process
Multi-broker environments create fragmented data. We consolidate every IOR number, every broker’s entries, into one audit and one CAPE submission process.
No Integration required
PDFs, emails, invoices, ACE exports, broker records, send us what you have. No IT project, no special format, no onboarding delay.
Pricing
Simple pricing, no minimum volume.
Transparent per-entry fees with a discount for SaaS commitment. No integration required, no onboarding cost, no hidden fees.
Starter
Review + Observations
$100 per entry
Full Step 1&2: ACE Review + Post-Entry Opportunities
Includes:
- Tariff stacking hierarchy review
- identification of CAPE Phase 1 elligability
- ACE Portal and Reporting access
- ACH Refund enrollment verification
- CAPE Declaration preparation & submission
- Multi-broker data consolidation
Full Service
Review + Observations + Post-Entry Filing
$100 per entry
All three steps for end-to-end CAPE management
Everything in Starter, plus:
- Post-Entry Document Ingestion
- PSC processing
- CBP information request support
- Recalculation of IEEPA refund estimate
- * Broker Fee passed through
SaaS Commitment
10-20% discount
For Annual Post-Entry Audit
Includes:
- All ‘Full Service’ features
- KlearHub trade data infrastructure
- Ongoing post-entry audit tool
- Proactive liquidation timeline alerts
- Centralized multi-broker data layer
Watch our Live Sessions on this topic:
Section 232 April 2026: What changed, what got removed, and what it cost…
IEEPA Refunds done Right: Know your Data Before CAPE Goes Live