Frequently asked questions
20+ plain-English answers covering CAPE eligibility, 180-day deadlines, IOR status, drawback cost, and customs broker engagements. Each links to the calculator or guide that digs deeper.
What is the difference between CBP Form 3461 and 7501?
CBP Form 3461 is the entry document that releases cargo. Form 7501 is the entry summary that declares duty and classification. 3461 comes first, 7501 follows within 10 working days.
How do I register in the ACE portal?
Register for the CBP ACE Secure Data Portal at ace.cbp.dhs.gov. Importers need an IOR number, EIN, and CBP Form 5106 on file. Registration is free and takes 1 to 3 business days.
Can Amazon FBA sellers get tariff refunds?
Yes, Amazon FBA sellers can claim CAPE IEEPA refunds if they were the importer of record on their 7501. Sellers who shipped DDP with supplier as IOR cannot claim directly. Drawback eligibility is usually limited for FBA.
Can my customs broker file a refund on my behalf?
Yes. A licensed customs broker can file CF-19 protests and CAPE refund claims with a valid Power of Attorney under 19 CFR 111 and 19 CFR 141.31.
Do I need to give a Power of Attorney to the customs broker?
Yes. Under 19 CFR 141.31 and 19 CFR 111.29, a valid Power of Attorney is required before a customs broker can file any customs business on your behalf, including CAPE refunds and CF-19 protests.
What entries qualify for CAPE Phase 1?
CAPE Phase 1 covers unliquidated IEEPA-window entries and liquidated entries within the 180-day CF-19 protest window. Eligibility rules, entry types, and exclusions.
Will consumers get a $2,000 tariff rebate check?
A $2,000 consumer tariff rebate has been proposed but is not law as of April 2026. No check is scheduled. Tariff refunds currently flow only to US importers of record through the CBP CAPE portal.
How much does a duty drawback consultant charge?
Duty drawback consultants typically charge 8 to 20 percent contingency on recovered duty. Flat fee, hourly, and hybrid models also exist. What drives the rate and when each model makes sense.
What's the difference between duty drawback and a tariff refund?
Duty drawback refunds 99 percent of duty on exported or destroyed goods under 19 USC 1313. Tariff refunds recover duties paid in error. Both have separate rules and windows.
Is first sale valuation still legal?
Yes. First sale valuation remains lawful under 19 USC 1401a and Nissho Iwai precedent. The Cassidy bill threatens to eliminate it but has not passed. Compliance rules still apply.
Is GSP coming back?
The Generalized System of Preferences lapsed December 31, 2020 and has not been reauthorized by Congress as of April 2026. Retroactive refunds would apply if renewed. Pending bills track below.
How long does a tariff refund take?
CBP CAPE processes IEEPA refund claims in 60 to 90 days per entry. Timelines, ACH payment windows, and factors that slow down your refund.
Am I the importer of record?
The importer of record is the entity listed on CBP Form 7501 Block 22 with responsibility for entry, duty payment, and compliance under 19 USC 1484. Check your 7501 to confirm.
When does an entry liquidate?
CBP entries automatically liquidate approximately 314 days after entry date under 19 USC 1504. Suspensions extend this. Find liquidation status in ACE or on the CBP Liquidation Bulletin.
Are MPF and HMF refundable?
Merchandise Processing Fee (MPF) is refundable via drawback under 19 USC 1313 but typically not via CAPE IEEPA refunds. Harbor Maintenance Fee (HMF) is generally never refundable for consumption entries.
Does CBP pay interest on tariff refunds?
Yes. CBP pays interest on excess duty refunds under 19 USC 1505(c) at the IRS underpayment rate, running from date of deposit to date of refund. Rate updates quarterly.
Can I still get a Section 232 exclusion?
No. The Section 232 steel and aluminum exclusion window closed February 10, 2025 by Presidential Proclamation 10896. Existing exclusions remain valid until expiry; no new requests accepted.
Are Section 301 tariffs included in the IEEPA refund?
No. Section 301 China tariffs were not struck down and are not refundable under the April 2026 CBP CAPE program. Only IEEPA duties from 2025 to Feb 20, 2026 qualify.
What is tariff engineering?
Tariff engineering is the legal practice of designing or modifying a product so it classifies under a lower-duty HTSUS heading. Sanctioned by CBP under Merritt v. Welsh (1882) when the product is what it appears to be.
Who qualifies for a tariff refund?
US importers who paid IEEPA-era duties between 2025 and Feb 20, 2026 may qualify for CBP CAPE refunds. Eligibility rules, entry types, and filing windows.
Want a per-entry estimate?
Run the IEEPA refund calculator or upload your CBP Form 7501 for line-level extraction.