For the reciprocal tariff, should I use drawback or the CAPE refund?

It depends on your entries and exports. The CAPE refund returns the full duty with interest and does not require an export, which suits most importers. Drawback recovers 99% and requires an export or destruction, but it does not depend on the refund process or its review timeline. The two cannot be used on the same entry, because an entry designated on a drawback claim is ineligible for the CAPE refund, so the sequencing has to be planned. We model both and file the one that recovers the most for you.

Tariffs

IEEPA tariffs, recover what you paid.

Q: Are IEEPA tariffs eligible for duty drawback?

It depends on which IEEPA tariff. The reciprocal tariff is drawback eligible, and so are the Brazil action and the Russia-related duties on goods from India. The fentanyl and trafficking tariff on imports from China, Mexico and Canada is not eligible, because the order that imposed it bars drawback. So the answer turns on the specific IEEPA action and your classifications, which is exactly what an assessment confirms.

Q: How do I recover the IEEPA duties I paid?

There are two paths. Where the IEEPA duty is drawback eligible, such as the reciprocal tariff, you can recover 99% through duty drawback when the goods, or a qualifying substitute, are exported or destroyed within five years. Separately, after the Supreme Court struck the IEEPA tariffs down in February 2026, CBP opened a refund of duties already paid through the CAPE process in the ACE portal, with interest. For the fentanyl tariff, which drawback cannot touch, the CAPE refund is the route.

Q: What is the CAPE refund process?

CAPE is the process CBP uses in the ACE Secure Data Portal to refund IEEPA duties after the tariffs were struck down. The importer of record, or an authorized broker, files a CAPE declaration listing the affected entries. CBP removes the IEEPA Chapter 99 tariff numbers, recalculates the duty as if the charge had never been assessed, and issues a consolidated refund with interest under 19 CFR 24.36, generally within 60 to 90 days of accepting the declaration.

IEEPA is not one tariff, and it is not one answer for drawback. The reciprocal tariff is drawback eligible. The fentanyl and trafficking tariff is not. And after the Supreme Court struck the IEEPA tariffs down in February 2026, duties already paid can also be recovered through CBP's CAPE refund process in ACE. Knowing which path applies is where the money is.

ReciprocalDrawback eligible, recover 99% on export

FentanylDrawback barred, recover through CAPE

$166BIEEPA duties collected, now recoverable

What it is

One authority, several tariffs, different rules.

The IEEPA tariffs

Beginning in 2025, the administration used the International Emergency Economic Powers Act to impose several sets of additional duties: the reciprocal tariff applied broadly across trading partners, the fentanyl and trafficking tariff on imports from China, Mexico and Canada, and country actions tied to Brazil and to Russian oil purchased through India. They share one authority but not one rulebook, and for drawback the difference matters.

On February 20, 2026 the Supreme Court held that the IEEPA tariffs exceeded the authority the statute grants, and collection ended days later. CBP has since built a process to refund the duties already paid. Across the program CBP has reported roughly 166 billion dollars collected from about 330,000 importers. If your company paid any of it, there is money to recover, and the right path depends on which tariff you paid.

Drawback eligibility

Two tariffs, two answers.

The single most important distinction on this page. One IEEPA tariff is drawback eligible; the other is barred from it by its own order.

Reciprocal tariff

The IEEPA reciprocal tariff is drawback eligible. When the duty-paid import, or a qualifying substitute of the same 8-digit HTS, is exported or destroyed within five years, the claimant recovers 99% of the reciprocal duty under 19 U.S.C. 1313. The same holds for the Brazil action and the Russia-related duties on goods from India.

Drawback eligible. Recover 99% on export.

Fentanyl and trafficking tariff

The IEEPA fentanyl and trafficking tariff on imports from China, Mexico and Canada is not drawback eligible. The executive order that imposed it expressly bars drawback, so there is no export-based recovery on those duties. What paid fentanyl duty can do is come back through the CAPE refund below.

Drawback barred. Recover through CAPE.

The refund path

The CAPE refund, in ACE.

Because the IEEPA tariffs were struck down, duties already paid can be refunded directly through CBP's CAPE process in the ACE Secure Data Portal, with interest. It applies to both tariffs, and for the fentanyl tariff it is the only route. It consolidates a refund across many entries into a single payment rather than reopening each one.

1. Identify the entries

Every entry where IEEPA duty was paid is a candidate, and the affected lines carry the IEEPA Chapter 99 tariff numbers. This is a data exercise first: pull the entry history, isolate the IEEPA duty, and confirm nothing on those entries has been committed to a drawback claim, since an entry designated on a drawback claim is not eligible for the CAPE refund.

2. File the CAPE declaration

The refund is claimed by uploading a CAPE declaration, a structured file that lists the entries, through the ACE portal. CBP then removes the IEEPA Chapter 99 numbers from those entries and recalculates the duty as if the IEEPA charge had never been assessed.

3. Refund with interest

CBP issues the difference back as a consolidated refund, with interest calculated under 19 CFR 24.36, generally within 60 to 90 days of accepting the declaration. Claims can be reviewed and documentation requested, so the declaration needs to be accurate and supportable.

Drawback or CAPE

For the reciprocal tariff, you have a choice.

The fentanyl tariff has one route, the CAPE refund. The reciprocal tariff has two, and the better one depends on your entries and your exports.

Duty drawback

Recovers 99% of the reciprocal duty, and requires that the goods, or a qualifying substitute, are exported or destroyed. It runs on its own track, independent of the refund process and its review timeline, and it reaches back five years from importation.

How duty drawback works

CAPE refund

Returns the full duty with interest and does not require an export, which suits most importers. It depends on CBP accepting the declaration and can be subject to review. An entry used for the CAPE refund cannot also be used for drawback, so the two do not stack.

Estimate your CAPE refund

How Alliance helps

The same data discipline, pointed at your refund.

We find the most recovery, and file it

Recovering IEEPA duty is an entry-data problem, which is what a drawback firm does all day. We pull your entry history, separate the reciprocal duty from the fentanyl duty line by line, model drawback against the CAPE refund for the entries that qualify for both, and file whichever recovers more, as your broker of record.

Start with a free assessment

Estimate before you file

Our IEEPA refund calculator gives you an estimate straight from your own entry data, processed privately in your browser. If the number is worth pursuing, our licensed brokers take it from there.

Open the IEEPA refund calculator

Common questions

IEEPA tariffs and refunds, answered.

Are IEEPA tariffs eligible for duty drawback?

It depends which one. The reciprocal tariff is drawback eligible, as are the Brazil action and the Russia-related duties on goods from India. The fentanyl and trafficking tariff on China, Mexico and Canada is not, because the order that imposed it bars drawback. The answer turns on the specific IEEPA action and your classifications, which an assessment confirms.

How do I recover the IEEPA duties I paid?

Two paths. Where the duty is drawback eligible, like the reciprocal tariff, you recover 99% through drawback when the goods or a qualifying substitute are exported within five years. Separately, after the tariffs were struck down in February 2026, CBP opened a refund of duties already paid through the CAPE process in ACE, with interest. For the fentanyl tariff, which drawback cannot touch, CAPE is the route.

What is the CAPE refund process?

It is how CBP refunds IEEPA duties in the ACE Secure Data Portal after the tariffs were struck down. The importer of record, or an authorized broker, files a CAPE declaration listing the entries. CBP removes the IEEPA Chapter 99 tariff numbers, recalculates the duty as if the charge had never been assessed, and issues a consolidated refund with interest under 19 CFR 24.36, generally within 60 to 90 days of acceptance.

For the reciprocal tariff, should I use drawback or CAPE?

It depends on your entries and exports. CAPE returns the full duty with interest and needs no export, which suits most importers. Drawback recovers 99% and requires an export, but runs independent of the refund process. The two cannot be used on the same entry, since an entry on a drawback claim is ineligible for the CAPE refund, so we model both and file the one that recovers the most.

What about the fentanyl tariff?

The IEEPA fentanyl and trafficking tariff on China, Mexico and Canada is not drawback eligible; its order bars drawback. Duties paid on it are recovered through the CAPE refund process, not through drawback.

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Recover your IEEPA duty

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