Hit by US Tariffs Canadian Business Owners’ Guide to Claim Refunds for U.S. IEEPA Tariffs

Many Canadian business owners were struck by 35% tariffs imposed by US President Donald Trump under the International Emergency Economic Powers Act (IEEPA). However, the US Supreme Court invalidated the IEEPA tariffs on February 20, 2026, and ordered refunds. The U.S. Customs and Border Protection (CBP) stopped collecting them on February 24, 2026. Two months later, on April 20, 2026, it began Phase 1 of the refunding of IEEPA tariffs collected from February 4, 2025, to February 24, 2026.

How IEEPA Tariff Refunds Work

The IEEPA tariff refund would have been messy under the existing refund process, which requires importers to submit a request for each entry. Given the sheer volume of entries during the tariff period, CBP decided to shift the refund process from a per-entry basis to a per-importer/customs broker basis. It even introduced a dedicated system, called Consolidated Administration and Processing of Entries (CAPE).

One importer can have multiple entries for all consignments during the tariff period. They can consolidate all their entries for which they paid the IEEPA tariff in a structured CSV file format provided by CBP, gather proof of payment, and submit it to the new CAPE system.

The CBP has created the CAPE system on the Automated Commercial Environment (ACE) portal, where it stores and manages all import data and filings. The system will match import filings to refund requests submitted on CAPE and process eligible refunds, reducing administrative friction. Incomplete or inaccurate entries may lead to rejection of individual items or the entire submission.

Eligibility to Claim Tariff Refunds

It is important to note that not all tariffs are refundable. A temporary tariff of 10% imposed in place of the IEEPA tariffs under Section 122 and tariffs imposed on steel, aluminum, semiconductors, copper, and other goods on national security grounds under Section 232 are nonrefundable and cannot be claimed.

IEEPA duties will be refunded in stages, with Phase 1 processing refunds for only unliquidated entries and certain entries within 80 days of liquidation.

Note: When an importer imports goods over $2,500, they post a bond with CBP. Under that bond, they pay estimated duties when goods enter the country and the final amount within a year, thereby liquidating that entry. For goods below $2,500, entries are liquidated upon payment of estimated duties.

Who Can Claim the Refund?

Only Importers of Record (IoR) and authorized customs brokers can claim refunds. IoRs are the business owners who own the goods and ensure they comply with all customs and legal requirements. A customs broker can act as the importer of record for multiple business owners.

If a Canadian exporter shipped the goods to a US importer, the Canadian business cannot file a refund claim directly. It will have to work with the US customer to file a claim and work out the refund process with them.

How Canadian Importers Can Request IEEPA Tariff Refunds

Canadian businesses that were hit by the IEEPA tariff can follow the steps below to request refunds:

• Identify the IoR or customs broker. They may be a Canadian entity or a US customer.
• Coordinate with the US customer to file the claim.
• Prepare a list of entries eligible for IEEPA refunds, matching each entry with the documentation originally filed with CBP. Submit this document as a CAPE Declaration in the structured CSV file.

Each CAPE Declaration can include up to 9,999 customs entries. Multiple Declarations may also be submitted. Brokers can submit a single declaration for all entries across multiple importers of record.

The CBP will review the CAPE declaration and approve or reject it. If approved, the claims will be processed within 60 to 90 days. If the CBP demands additional review, the refund could be delayed. The key to getting your refund request approved is to file it right the first time, with detailed entry summaries and proof of IEEPA duties paid.

Seek Professional Help

Although the CAPE process has streamlined refunds, the challenge lies in compiling eligible entries. Each entry should meet the compliance requirement because a single mistake could result in the entire submission being rejected.

For a business having large import programs, compiling the list may require a professional. They may need to coordinate among multiple brokers, reconcile entry records across multiple ports, and sequence their filings to avoid locking out eligible entries due to an improperly structured declaration.

An experienced tariff advisor can help businesses throughout the CAPE refund process, from identifying eligible entries to preparing the CAPE declaration and addressing customs and trade considerations before, during, and after the refund process.

Contact Edelkoort Smethurst CPAs LLP in Burlington to Help You File for IEEPA Tariff Refund

Talk to a professional accountant to help you collect all the necessary information needed to file a CAPE declaration. At Edelkoort Smethurst CPAs LLP, our accountants can provide services such as filing returns and managing compliance documentation. To learn more about how Edelkoort Smethurst CPAs LLP can provide you with the best cross-border tax and accounting services, contact us online or by telephone at 905-517-2297.