U.S. Tariff Refund Portal Now Open: A Step-by-Step Guide for Canadian Businesses to Reclaim IEEPA Duties Paid Since February 2025

What This Means for You

If your Canadian business paid U.S. tariffs as the Importer of Record on goods crossing the border between February 4, 2025 and February 24, 2026, you may now be eligible to apply for a refund — with statutory interest — through a brand-new electronic portal that U.S. Customs and Border Protection opened on April 20, 2026. The window for filing is narrow, the documentation requirements are unforgiving, and the biggest mistake we are seeing in the first week of the portal's operation is Canadian shippers assuming their U.S. customs broker will handle it automatically. They will not, unless you ask in writing and authorize the filings.

Below is the action plan by company type. The figures and forms below assume you are filing under the U.S. Court of International Trade orders that flow from the Supreme Court's February 2026 ruling invalidating tariffs imposed under the International Emergency Economic Powers Act. If you also paid Section 232 (steel and aluminum) or Section 301 (China) tariffs, those are separate programs and not eligible under this CAPE process.

If You Are a Canadian Exporter Acting as the U.S. Importer of Record

This is the single biggest category of eligible Canadian claimant, and the one where the refund opportunity is largest. If you sold to U.S. buyers on Delivered Duty Paid (DDP) terms, your company name is on the entry and the refund flows back to you, not to your U.S. customer.

Immediate action this week:

Pull your U.S. customs entries (CBP Form 7501) for every shipment between February 4, 2025 and February 24, 2026. Your customs broker has them on file. Ask for an electronic export of all entries with the IEEPA duty code. The data point you want is on Box 39 ("Total Duty"), separated out by HTS line.
Tally the IEEPA-specific duties paid. A Canadian manufacturer shipping $4 million in non-CUSMA-compliant goods over the 12-month tariff period at the 25% IEEPA rate would have paid roughly $1 million in tariffs eligible for refund, plus statutory interest of approximately 4% to 5% annualized — putting the recoverable total in the $1.04 million to $1.05 million range.
Confirm you were the Importer of Record (IOR) at the time of entry. The IOR is the entity legally liable for duties; it is not always the seller. Pull your commercial invoices and Incoterms — DDP, DDU, and most "ship-to" arrangements where the Canadian seller cleared customs leave you as the IOR.
Authorize your U.S. customs broker in writing to file the refund through the CAPE tool in the ACE Secure Data Portal. A power of attorney or specific written authorization is required; verbal instructions are not enough. Without this authorization, the broker has no legal basis to file on your behalf.

What to prepare:

Banking information for receipt of refund. CBP issues refunds electronically by ACH to the IOR's U.S.-dollar bank account. If you do not have one, your Canadian bank can typically open a U.S.-dollar receiving account within 5 to 10 business days. Wire-transfer alternatives are slower and costlier.
Full documentation chain for each entry. CBP can request: the original commercial invoice, packing list, bill of lading, proof of payment of duty, and the entry summary. Refund claims that cannot be supported with documentation are rejected, not delayed.
Tax accrual reversal entry. If you booked the IEEPA duties as a cost of goods sold in 2025 or early 2026 (as most Canadian GAAP and IFRS preparers did), a refund creates a recovery that flows to current-year income. Discuss the tax treatment with your accountant before filing — the refund itself is not taxable in Canada, but the reversal of a previously deducted expense generally is.

Refund timeline:

CBP estimates 60 to 90 days from a clean submission to electronic deposit. Filings with documentation gaps are kicked back into a "request for information" queue that can extend the cycle by another 30 to 60 days. The portal is processing first-in-first-out, so early filers will see money in late June or July 2026; back-of-the-queue filings risk slipping into the fall.

If You Are a Canadian Importer Who Paid U.S. Tariffs on Inputs You Re-Imported

A subset of Canadian manufacturers — primarily in automotive, machinery, and processed food — sent components or work-in-process to U.S. contract manufacturers, paid IEEPA tariffs at the U.S. border, and then re-imported the finished goods into Canada. If your company name appears on the U.S. entry, you are the IOR and eligible.

Practical steps:

Map your cross-border bill of materials for the affected period. Each line item that crossed the border with an IEEPA duty applied is potentially recoverable.
Reconcile against your supplier invoices. If your U.S. contract manufacturer was the IOR (some agreements assign duty liability to the manufacturer), the refund flows to them, not to you. Your contract may require they pass it through; if not, this is a renegotiation conversation.
Document the re-import flow into Canada. A refund claim will not affect Canadian counter-tariffs you paid to CBSA — those are separate, and Canada has its own remission orders for vehicles and certain inputs that you should be checking against.

If You Are a Small Business or Sole Proprietor Who Imported Through a Broker

If your annual U.S. import value was under $500,000, you may not have a customs broker at all — or you may have used a freight forwarder's brokerage service. The refund process is still open to you, but the practical path is different.

Immediate action:

Contact your freight forwarder or customs brokerage. Ask for the entry numbers for every shipment in the eligible window. They should be able to produce a CBP Form 7501 PDF for each one within 48 hours.
Get a quote for the refund filing. Customs brokers typically charge $50 to $150 per entry filed through CAPE, or a bundled fee of 5% to 10% of the recovered amount on contingency. For small shippers with under $5,000 in eligible duties, the contingency model is usually the right call.
Check whether DIY filing is realistic. The CAPE tool requires an ACE Portal account for the IOR, two-factor authentication, and the ability to upload supporting documents in the prescribed format. CBP does not provide telephone support for portal filings. If you have never logged into ACE before, plan on 4 to 6 hours to set up and complete a single filing — usually not worth it for fewer than three to four entries.

Resources:

CBP's CAPE landing page and step-by-step user guide are linked from the main IEEPA refund page on cbp.gov.
The Canadian Federation of Independent Business (CFIB) has published a free plain-language walkthrough for member businesses at cfib-fcei.ca.
Refdesk's Canadian Business Tools and Calculators page links to currency-conversion and duty-recovery worksheets that may help you estimate eligible amounts before engaging a broker.

For All Canadian Businesses: Cash-Flow Implications

Even businesses that did not import directly are affected by this refund cycle, because the recovery is flowing through the same supplier-customer chains that were squeezed by the original tariffs. If you sold inputs to a U.S. customer at a price that absorbed part of their tariff exposure, you have a commercial conversation to start about whether any of that recovered margin should flow back to you.

Practical steps:

Audit your 2025 price-concession letters. Many Canadian suppliers issued temporary discounts to U.S. customers explicitly tied to "tariff burden sharing." Those agreements typically did not anticipate refunds; the default contract law position is that the IOR keeps the refund. But where the price concession was framed as a pass-through, you may have an argument for partial recovery.
Talk to your accounts receivable team. U.S. customers are now expecting refund cash; some are already trying to renegotiate go-forward pricing on the assumption that pre-2026 tariff costs will reverse. Hold the line until the refund actually clears the IOR's account.
Plan your treasury for the lump-sum inflow. A $500,000 refund hitting in July is a working-capital event; it is not recurring revenue. The most common errors we see are using refund cash to fund operating expenses that should have been right-sized after the tariffs first hit.

The News: What Happened

According to RSM Canada, on April 20, 2026, U.S. Customs and Border Protection (CBP) activated the first phase of its new Consolidated Administration and Processing of Entries (CAPE) system — the exclusive electronic mechanism for requesting refunds of duties paid under tariffs imposed pursuant to the International Emergency Economic Powers Act (IEEPA). As reported by CP24, this development followed the U.S. Supreme Court's February 2026 ruling invalidating those tariffs, as well as subsequent orders from the U.S. Court of International Trade directing CBP to issue refunds.

The Canadian Federation of Independent Business (CFIB) confirmed that Canadian businesses that served as the "Importer of Record" and paid U.S. tariffs on non-CUSMA-compliant goods under the IEEPA between February 4, 2025 and February 24, 2026 may now be eligible for refunds through the new portal. According to RSM, beginning April 20, importers of record (or their authorized customs brokers) may submit IEEPA tariff refund requests electronically through the ACE Secure Data Portal using the CAPE tool.

CBP indicated, according to multiple customs-law publications including coverage from National (the Canadian communications and public-affairs firm), that to be eligible for a refund, the claimant must have been registered as the importer of record with CBP at the time the duties were paid, or have authorized the customs broker who filed the entries on their behalf. Once a submission is accepted, CBP anticipates refunds to be issued electronically within approximately 60 to 90 days, inclusive of statutory interest, subject to standard compliance review.

The opening of the refund portal sits alongside parallel Canadian relief measures. According to coverage of recent federal action, the Government of Canada finalized the United States Surtax Remission Order (Motor Vehicles 2026) on April 8, 2026, extending relief from Canada's 25% counter-tariffs on certain U.S.-manufactured vehicles for an additional year. CFIB has separately reported that Canadian businesses' nominal exports to the United States were 11.1% lower at year-end 2025 than levels reported in March 2025, underscoring the scale of the trade disruption that the refund program is intended to partially unwind.

Analysis: Why This Matters

Based on our analysis of the IEEPA refund mechanics and the existing Canadian importer-of-record patterns, this is the single largest cross-border refund event Canadian businesses have faced in at least a generation. The 12.5-month tariff window covered by the refund order coincides almost exactly with peak IEEPA enforcement; estimates from Canadian trade-policy analysts suggest Canadian-IOR-paid duties recoverable through CAPE could exceed CAD $3 billion to $4 billion in aggregate, with the largest concentrations in machinery, transportation equipment, and processed agricultural exports.

Here is why this matters for Canadian businesses beyond the refund itself: the speed and discipline of your filing will directly affect your 2026 working-capital position. Companies that file in the first 30 days of the portal being open will see refunds in June and July; companies that wait until the fall will compete with a much larger queue and likely see delays into Q4 or beyond. The carrying cost of an unrecovered $1 million refund, at typical Canadian SME credit-line rates of 7% to 9%, runs $5,800 to $7,500 per month — money that compounds the longer the filing slips.

Historical Context

Refund processes for invalidated U.S. tariffs are not new — there were narrow refund windows after the 2018-2019 Section 232 review process and after the 2020 List 4A litigation on China tariffs. But the scale is different here: IEEPA covered virtually all non-CUSMA Canadian exports for more than a year, where prior actions covered narrower product categories. The CAPE system itself is also new infrastructure, designed in response to court pressure to centralize what had been a fragmented refund process across 328 ports of entry.

What Happens Next

Based on our analysis of the legislative and litigation timeline, three developments are likely over the next 90 days. First, CBP will publish technical guidance updates as the portal handles its first wave of submissions; small process changes are likely in May and June. Second, several U.S. customs broker associations have signalled they will pursue litigation if refund processing slips beyond 120 days, which could expedite later filings. Third, there is still residual political risk that a future U.S. administration could attempt to delay or constrain payouts; the safest path for any Canadian business with a recoverable claim is to file early and to keep the refund cash, once received, in a segregated account until the refund order is no longer subject to appeal.

Your Action Plan

Immediate (This Week):

Email your U.S. customs broker to request a list of all entries where your company was the IOR between Feb 4, 2025 and Feb 24, 2026
Sign the broker's CAPE filing authorization (typically a one-page POA addendum)
Open or confirm a U.S.-dollar receiving bank account capable of accepting ACH deposits
Calculate your gross IEEPA exposure (sum of IEEPA-coded duties from all qualifying CBP Form 7501 entries)

Short-term (This Month):

Reconcile your customs broker's entry list against your own shipping records
Consult your accountant on the Canadian tax treatment of the refund and any required accrual reversal
If you sold DDP to U.S. customers, confirm your contracts and pricing terms — the IOR keeps the refund unless a contract says otherwise
File the CAPE refund claim, or have your broker file on your behalf

Long-term (This Year):

Track your filing through the ACE Portal status tools; respond promptly to any CBP requests for information
When the refund clears, segregate the funds until the underlying refund order is no longer subject to appeal
Reassess your cross-border pricing and Incoterms for 2026-2027 — many Canadian exporters who shifted away from DDP during the tariff period will want to reconsider that decision
Review whether any Canadian counter-tariff remission orders (vehicles, steel inputs, etc.) apply to your business and file with CBSA

Other Perspectives

Federal Government View:

Federal Finance and Trade officials, according to CFIB summaries of Government of Canada communications, have publicly encouraged eligible Canadian businesses to use the U.S. CAPE portal and have separately moved to extend Canadian counter-tariff remission orders, signalling that Ottawa views the refund cycle as part of a broader normalization of cross-border trade.

Customs Broker Industry View:

According to commentary from RSM and other accounting and customs-advisory firms, brokers expect a surge in filings through May and June 2026 and have warned clients that the 60-to-90-day refund timeline applies only to clean filings — incomplete documentation will materially extend the process.

Small Business View:

The Canadian Federation of Independent Business (CFIB) has published a dedicated resource page for member businesses navigating the refund process, noting that for many small importers the recoverable amounts are material relative to their margins and that early filing is critical to capture the full cash-flow benefit.

U.S. Customer View:

U.S. importers and customers are pursuing their own refund claims in parallel where they were the IOR, and according to several trade-press accounts, are also testing renegotiation conversations with Canadian suppliers on go-forward pricing. The legal default — that the IOR retains the refund — has held in the early test cases.

Note: Including multiple perspectives doesn't imply all views are equally valid, but ensures readers can make informed judgments.

Corrections Policy

We strive for accuracy. If you find an error in this analysis, please email us at [email protected]. We will promptly investigate and correct any factual inaccuracies.

Updates:

No corrections to date (as of April 26, 2026)