⚠️ Update — June 2026: The IEEPA tariff refund situation is changing rapidly and remains in active litigation. The government has appealed the nationwide refund order to the Federal Circuit, and as of mid-June 2026 the court’s stay of its refund orders remains in place. Refunds for certain categories of entries — particularly “finally liquidated” entries (generally 180+ days past liquidation) and importers who have not filed suit at the Court of International Trade — may be delayed, handled differently, or uncertain. The details below cover the general CAPE process and typical costs, but your specific eligibility and timeline should be confirmed with a qualified specialist based on current rulings.
IEEPA & CAPE Duty Refund Costs: What Importers Need to Know in 2026
With CBP’s CAPE system live for IEEPA duty refunds, many importers are asking the same question: How much will it actually cost to recover my money?
While the refunds themselves can be substantial, there are real costs involved in preparing and filing claims. Understanding the pricing landscape helps you maximize your net recovery.
Why There Are Costs Involved
Filing CAPE declarations is not as simple as uploading a list of entry numbers. It requires:
- Proper ACE Secure Data Portal access and setup
- Accurate data compilation and CSV file preparation
- Coordination between importers and their original filing brokers
- Ongoing monitoring and potential responses to CBP inquiries
Most importers will work with a licensed customs broker or specialized service provider to handle this process.
Important: CAPE Filing May Not Cover Every Entry
While CAPE Phase 1 handles many non-final entries, recent court activity has created real uncertainty for some importers. CBP has taken the position that it may not be able to refund IEEPA duties on finally-liquidated entries without an importer-specific court order, and the government’s appeal has effectively split importers into those who filed suit at the Court of International Trade and those who didn’t — with different potential outcomes for each. If a meaningful portion of your duties sits in these categories, simply filing through CAPE may not be enough, and you may need additional legal steps to protect your claim. This is exactly the kind of situation where an experienced specialist’s guidance is worth the cost.
Common Pricing Models for IEEPA/CAPE Filings
1. Flat Fee Per Entry (Most Common for Smaller Claims)
Many providers charge a fixed fee based on the number of entries:
- Smaller claims: often a fixed fee for the first entry plus a lower per-entry fee for additional entries
- Larger or simpler batches: typically a flat per-entry rate
Reported figures generally fall in the $125–$350 per-entry range, but pricing varies significantly by provider and complexity — always get current quotes.
2. Contingency / Success Fee Model
Some firms work on a percentage of the refund recovered (commonly in the mid-single-digit percentage range, though this varies). This model is more common for larger claims but means you pay more as your refund amount increases.
3. Hybrid Models
A combination of a smaller flat fee + a reduced percentage. This is becoming popular as it balances risk and reward for both parties.
Factors That Affect Your Total Cost
- Number of entries — More entries = higher total fees in flat-fee models
- Total refund amount — Larger refunds may qualify for better percentage rates
- Complexity — Entries requiring additional documentation or responses to CBP will cost more
- Who files — Using the original broker who filed the entries is often required or more efficient
- Timeline pressure — Rush filings or last-minute coordination usually carry premium pricing
How to Maximize Your Net Recovery
- Get quotes from multiple experienced providers — pricing varies significantly
- Ask specifically what is included (data prep, filing, responses to CBP, etc.)
- Understand whether the fee is charged upfront or only upon successful refund
- Confirm which of your entries are actually eligible under the current CAPE phases and rulings
- Work with brokers who already have your entry data and ACE access
- Consider bundling multiple phases if you have entries across different liquidation periods
Final Thought
IEEPA/CAPE refunds represent a meaningful cash flow opportunity for many importers. However, the net amount you actually keep depends heavily on who you work with, how the fees are structured, and — increasingly — on where your entries fall within an evolving legal landscape.
Taking the time to understand pricing models, confirm your eligibility, and get competitive quotes can make a significant difference in your final recovery.
Not sure which of your entries are recoverable — or how much it’ll cost to claim them?
Get a free, no-obligation assessment and connect with a vetted specialist experienced in IEEPA and CAPE refunds.