In April 2025, the U.S. government imposed sweeping 35% reciprocal tariffs under the International Emergency Economic Powers Act (IEEPA). For Amazon sellers who import goods — from any country, not just China — these tariffs landed directly on your cost of goods. Margins compressed overnight. Many sellers raised prices, absorbed losses, or stopped importing certain SKUs entirely.
Then, in a significant legal development, the U.S. Court of International Trade struck down those IEEPA tariffs as exceeding executive authority. The ruling means approximately $166 billion in duties collected across 53 million shipments between April 2025 and February 2026 are now eligible for refund — and CBP's refund portal went live on April 20, 2026.
If your business imported goods into the U.S. during that window and you were the Importer of Record, you may have a meaningful refund coming. This guide explains exactly who qualifies, what's excluded, and the precise steps to file before your window closes.
CBP estimates roughly $127 billion — including statutory interest — is eligible for Phase 1 refunds. That money goes back to the importers who claimed it, not automatically. You have to file.
What Are the IEEPA Tariff Refunds?
The IEEPA tariff program imposed a blanket 35% reciprocal tariff on imports from dozens of countries starting in April 2025. Unlike the older Section 301 China tariffs or Section 232 steel and aluminum tariffs — which have separate legal histories and are not part of this refund — IEEPA tariffs were challenged in federal court on the grounds that the statute doesn't grant the executive branch authority to impose broad tariffs as a trade tool.
The Court of International Trade agreed. Following that ruling, CBP (U.S. Customs and Border Protection) established a formal refund program. Phase 1 covers unliquidated entries — shipments whose customs entries are still open — as well as entries liquidated within the past 80 days. Older liquidated entries can still be challenged via protest, but that 180-day window from liquidation date is firm.
- IEEPA 35% reciprocal tariffs: eligible for refund
- Section 301 (China-specific tariffs, 25%–145%): NOT eligible
- Section 232 (steel and aluminum): NOT eligible
- De minimis shipments (under $800): ineligible by definition, as no formal entry was filed
This distinction is critical for Amazon sellers sourcing from China. The Section 301 tariffs that drove up costs on Chinese-manufactured goods remain in place and are not part of this refund. The IEEPA refunds apply to the additional 35% reciprocal rate applied to goods from all affected countries — including many non-China manufacturing countries like Vietnam, India, and Bangladesh that Amazon sellers shifted sourcing to during previous tariff rounds.
Who Qualifies: The Importer of Record Requirement
The single most important concept in this refund process is the Importer of Record (IOR). CBP will issue refunds only to the entity that was legally designated as the IOR on the customs entry at the time of import. This is not necessarily the company that purchased the goods. It is the entity named on the CBP Form 7501 (Entry Summary) and responsible for paying duties.
If your business was the IOR
If your company (not your freight forwarder, not Amazon, not your supplier) was listed as the Importer of Record on your shipments, you are the eligible claimant. Your licensed customs broker likely has records of all your entry numbers. Gather those, and you can file directly through CBP's ACE Portal or have your broker file on your behalf.
If Amazon was the IOR on your FBA shipments
Some FBA sellers — particularly those using Amazon's import and logistics programs — may have had Amazon designated as the IOR. If that's the case, you were not the IOR and cannot directly claim a refund for those shipments. Amazon would be the eligible claimant and would need to process any refund on those entries. Contact Amazon Seller Support and your account manager to ask whether Amazon is pursuing refunds on entries where they acted as IOR on your behalf.
If you used a freight forwarder or customs broker
Your freight forwarder or customs broker filed your customs entries, but that doesn't make them the IOR — you (your business) should still be listed as the IOR on those entries. Your broker can confirm this quickly by pulling your entry records and showing you the IOR field on the Entry Summary. If you were the IOR, your broker can also file the CAPE Declaration on your behalf, which is the most common approach for sellers without direct ACE Portal experience.
If you're unsure whether your business was the IOR on your imports, the fastest path is to call your customs broker. They have your entry records and can tell you in minutes.
The Refund Process: Step by Step
CBP processes IEEPA refunds through CAPE (Consolidated Administration and Processing of Entries), a module within the ACE (Automated Commercial Environment) system — the same federal platform used for all customs filing in the U.S.
- 1Identify your eligible entries. Pull all customs entry numbers for shipments that arrived between April 2025 and February 2026 and were subject to IEEPA tariffs. Your customs broker or freight forwarder can generate this list. You need the actual CBP entry numbers (not Amazon shipment IDs).
- 2Confirm your ACE Portal access. You need an ACE Portal account with an "Importer" sub-account and a registered U.S. bank account on file with CBP for electronic refund payment. If you don't have this, your customs broker can file on your behalf using their ACE access.
- 3Prepare your entry list as a CSV file. Each CAPE Declaration can include up to 9,999 entries. If you have more, submit multiple declarations. The CSV format is specified in CBP's filing guidance at ace.cbp.gov.
- 4Submit the CAPE Declaration. Log in to ace.cbp.gov, navigate to the CAPE module, and submit your declaration with the attached entry list. You'll receive a confirmation number.
- 5Wait for processing. CBP's stated timeline is 60–90 days for valid declarations without compliance issues. The refund is paid electronically to your registered bank account.
- 6For liquidated entries older than 80 days: file a protest. If your entries were liquidated more than 80 days ago but less than 180 days ago, you must file a protest through ACE rather than a CAPE Declaration. Work with your customs broker — protests require more documentation and legal specificity.
Deadlines: Why This Is Urgent
The 180-day protest window is not a soft guideline. For entries that CBP has already liquidated (closed), the protest deadline is exactly 180 days from the liquidation date, and it does not move. An entry liquidated on October 1, 2025 has a protest deadline of March 30, 2026 — that window may already be closed for your earliest shipments.
Unliquidated entries have more flexibility, but they won't stay unliquidated forever. CBP can liquidate an entry at any time after the required one-year holding period, and once liquidated, the 180-day clock starts. The longer you wait, the more of your eligible entries will cross into the protest window or expire entirely.
- Phase 1 launched: April 20, 2026 — the portal is live now
- Unliquidated entries: file CAPE Declaration as soon as possible
- Entries liquidated within 80 days: eligible for CAPE Declaration
- Entries liquidated 80–180 days ago: file a protest (more complex, requires a broker)
- Entries liquidated more than 180 days ago: window closed, no refund available
The sellers who act in the first 30 days have the most options. Every week of delay converts potentially straightforward CAPE Declaration entries into more complex (and expensive) protest filings — or closes the window entirely.
Practical Guidance for Amazon Sellers
Do not try to file without your customs broker
The ACE Portal is a federal trade system built for licensed customs professionals. While importers can technically file directly, the CBP filing format requirements, the nuances of identifying which entries qualify, and the risk of errors that delay or invalidate a refund make this a case where working with your licensed customs broker is worth every dollar of their fee. If you don't currently have a customs broker relationship, contact the National Customs Brokers & Forwarders Association of America (NCBFAA) to find a licensed broker.
Watch for fraud
The U.S. Chamber of Commerce has explicitly warned that fraudsters are already targeting importers with offers to "process your tariff refund" for a large percentage fee or upfront payment. Legitimate customs brokers charge by the hour or by the filing — they do not take a percentage of your refund. If someone contacts you unsolicited about processing a tariff refund, do not engage.
Understand the tax implications
Tariff refunds are taxable income. If you expensed the original tariff payments as a cost of goods or business expense, the refund will need to be recognized as income in the year received. Consult your accountant before assuming the full refund amount lands on the bottom line untouched.
Document everything you submit
Keep copies of every entry number, every CAPE Declaration submission, every ACE Portal confirmation number, and all correspondence with CBP or your broker. If CBP triggers a compliance review on any of your entries, having clean documentation is the difference between a 60-day refund and a 6-month dispute.
What This Means for Your Amazon Business Going Forward
The IEEPA tariff refund is a one-time opportunity. But the broader story — that tariff policy can shift dramatically with little notice and that importers bear the cost — is permanent. The sellers who got hit hardest by the April 2025 tariffs were often those without clear visibility into their landed costs, without existing customs broker relationships, and without the financial modeling to quickly understand the margin impact of a sudden duty increase.
Two things will protect you better in the next tariff cycle: knowing your landed cost per unit at all times (not just at the moment of a price increase), and having a customs broker relationship you can pick up the phone and call when something changes. Both of those are infrastructure, not tactics. They take about two weeks to set up and they pay dividends every time the policy environment shifts — which, in recent years, has been frequently.
The IEEPA refund window is open. The math is straightforward. The process is manageable with a customs broker. The only variable is whether you act before your entries age out of eligibility.
If you're managing landed costs and inventory forecasting manually, SellerForge's Forecasting module tracks cost-per-unit and reorder timing across your ASIN catalog — so that when the next policy shift happens, you see the margin impact immediately rather than weeks later.
Frequently Asked Questions
What are IEEPA tariff refunds?
IEEPA tariff refunds stem from a U.S. Court of International Trade ruling that struck down the 35% reciprocal tariffs imposed under the International Emergency Economic Powers Act. CBP is now processing refunds for duties paid on eligible entries. Phase 1 launched April 20, 2026.
Do Section 301 China tariffs qualify for a refund?
No. Only duties assessed under the IEEPA 35% reciprocal tariff program are eligible. Section 232 (steel and aluminum) and Section 301 (China-specific) tariffs are not included in this refund program.
Who is eligible to claim an IEEPA tariff refund?
The Importer of Record (IOR) — the entity legally responsible for the shipment at the time of customs entry — is the eligible claimant. If a licensed customs broker filed the entry on your behalf, they can also file the CAPE Declaration for you. Retailers or end customers who were not the IOR cannot directly claim refunds.
How do I know if my Amazon FBA shipments qualify?
You qualify if your business (not Amazon) was listed as the Importer of Record on the customs entry. Check your import paperwork or ask your freight forwarder or customs broker. Sellers who used Amazon's own import arrangements where Amazon acted as IOR would not be the eligible claimant.
What is the deadline to claim an IEEPA tariff refund?
Entries that have already been liquidated (finalized by CBP) must have a protest filed within 180 days of the liquidation date. Unliquidated (open) entries can be addressed through a CAPE Declaration while they remain open. Do not delay — the 180-day protest window is firm.
How long does the refund take to process?
CBP estimates 60–90 days from acceptance of a valid CAPE Declaration for most refunds, unless a compliance review is triggered. Refunds are paid electronically to the bank account registered with CBP.
Amazon seller with 12+ years managing private label brands across 57 accounts and $60M+ in annual sales.
Get Amazon seller insights in your inbox
Practical strategies, SP-API updates, and AI tooling tips — no fluff.
No spam, ever. Unsubscribe anytime.
