Four factors determine your eligibility.

Importer of Record Status

The importer of record is the entity named on CBP Form 7501. This is the only entity legally authorized to claim a refund from CBP. If you use a customs broker, you are typically still the IOR -- they file on your behalf, not in their name.

If another entity imports on your behalf and is listed as IOR, the refund belongs to them -- not to you. This is common in drop-ship arrangements and some freight forwarding structures.

Country of Origin

IEEPA tariffs were imposed on imports from specific countries via executive order. The covered countries include China, Canada, Mexico, and virtually all countries subject to the April 2025 reciprocal tariffs. See the full country list with rates.

If all of your imports during the covered period came exclusively from countries not subject to IEEPA tariffs, your entries would not include recoverable IEEPA surcharges.

HTS Code Presence

IEEPA tariff surcharges are assessed under HTS headings 9903.01 and 9903.02. These codes appear on your CF-7501 entry summaries or your ES-003 report from CBP's ACE portal. If your entries include these codes, you paid IEEPA duties. See the HTS code reference guide.

Import Volume

There is no minimum threshold for IEEPA tariff refund eligibility. Whether your exposure is $10,000 or $50 million +, you may be eligible. However, the recovery path and economics differ significantly by volume tier.

Small importers (under $100K) may find self-directed recovery through CAPE most practical. Mid-range importers ($100K--$10M) benefit from a guided assessment. Large importers ($10M+) may have immediate capital options available. Learn about immediate capital.