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TariffLaw.org — Powered by TariffGuru.com IEEPA Legal Authority — Supreme Court Ruling — Importer Rights

The Law Is Clear. The Refund Is Yours.

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that the President exceeded his authority under the International Emergency Economic Powers Act by imposing tariffs. The Court of International Trade followed with a direct order to CBP to process refunds. The legal question is settled. The only remaining question is whether you file in time.

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60-90Day Payout Window
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The Law Protects You. But Only If You File.

The Supreme Court ruling established your legal right. The CIT order established the administrative process. Neither sends you a check. The refund only reaches your bank account if you file a correctly formatted CAPE Declaration through the ACE Secure Data Portal before your entries age out of Phase 1 eligibility.

The idea of America erupted from the colonies being taxed on imports. Those men and women became the first Americans. Two hundred and fifty years later the Supreme Court ruled these tariffs were imposed without legal authority. Your right to that money is as American as the country itself. File your claim.

The government has until approximately June 7, 2026 to appeal the CIT's nationwide refund order to the Federal Circuit. If an emergency stay is granted, all CAPE processing could be suspended while the appeal works through court — potentially for months. File before June 7. A CAPE Declaration accepted before a stay is already in the pipeline. One filed after may wait months or longer.
What statute did the Supreme Court rule on?
The Supreme Court ruled on the scope of 50 U.S.C. § 1702 — the International Emergency Economic Powers Act. The Court held 6-3 that the statute does not authorize the President to impose tariffs, even during a declared national emergency. The ruling was issued February 20, 2026 in Learning Resources, Inc. v. Trump. The decision is final and not subject to further appeal on the constitutional question.
What is the legal basis for statutory interest?
Statutory interest on customs duty refunds is governed by 19 U.S.C. 1505 and 26 U.S.C. 6621. Section 1505 requires CBP to pay interest on overpayments of customs duties. Section 6621 establishes the applicable IRS overpayment rate — currently 7% annually for non-corporations and 6% for corporations, compounded quarterly. These rates are published in the Federal Register quarterly by CBP and confirmed in Federal Register Vol. 90 No. 186 and Federal Register Document 2026-01175.
What is the legal deadline to file?
There is no single statutory filing deadline for CAPE Phase 1. However two legal risks create urgency: entries age out of Phase 1 eligibility continuously as they pass the 80-day post-liquidation window; and the government has until approximately June 7, 2026 to appeal the CIT's nationwide refund order. If an emergency stay is granted pending appeal, all CAPE processing could be suspended. Filing before June 7 is the only complete legal hedge against both risks.
Can the government refuse to pay after the ruling?
The government is bound by the CIT's order to process refunds through the CAPE system. Refusing to comply would constitute contempt of court. However the government can appeal the CIT's authority to issue a nationwide order covering all importers — not just those who filed suit. That appeal, if filed by June 7 and accompanied by an emergency stay request, could suspend processing while the Federal Circuit considers the jurisdictional question.
Does the ruling cover Section 301 tariffs on China?
No. Section 301 tariffs on Chinese goods were imposed under the Trade Act of 1974 — a different statute entirely — and were not before the Supreme Court in Learning Resources, Inc. v. Trump. Section 301 tariffs remain in effect and are not subject to refund under the current court orders. Only tariffs imposed under IEEPA Executive Orders are eligible for refund through the CAPE portal. A separate SCOTUS petition regarding Section 301 tariffs is pending — watch for developments in June 2026.

Three Legal Pillars of Your Refund Right

The Supreme Court ruling, the CIT order, and federal statutory interest law together establish your complete legal entitlement to an IEEPA tariff refund.

01

The Supreme Court Ruling

In Learning Resources, Inc. v. Trump, the Supreme Court held 6-3 that 50 U.S.C. § 1702 — the IEEPA statute — does not authorize the President to impose tariffs. Every dollar collected under those Executive Orders was collected without legal authority. The ruling was issued February 20, 2026 and is final. The Court did not order automatic refunds — it ruled on the legal question only.

02

The Court of International Trade Order

Following the Supreme Court ruling, the Court of International Trade in Euro-Notions Florida, Inc. v. United States issued a direct order to U.S. Customs and Border Protection to process refunds for all eligible importers — not just those who filed suit. CBP implemented the CAPE portal on April 20, 2026 as the administrative mechanism to comply with that order. The first refunds were issued May 11, 2026.

03

Your Statutory Right to Interest

Under 19 U.S.C. 1505 and 26 U.S.C. 6621, statutory interest accrues from the original entry payment date on all approved IEEPA refunds. The applicable rates are 7% annually for non-corporations and 6% for corporations, compounded quarterly. These rates are confirmed in Federal Register Vol. 90 No. 186 (September 29, 2025) and Federal Register Document 2026-01175 (January 22, 2026). CBP calculates and includes this interest automatically in your refund payment.


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Five Things Every Importer Must Know

The five technical pillars of IEEPA refund eligibility — covered in plain English. Liquidation status, ACH enrollment, entry formatting, interest calculation, and the Phase 1 exclusions that catch many filers off guard.

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1. Liquidation Status — Only unliquidated entries and entries liquidated within 80 days qualify for Phase 1.

2. ACH Enrollment — You must have a U.S. bank account registered in the ACE Secure Data Portal. This account must be separate from any ACH account used to pay duties to CBP.

3. Entry Formatting — All entry numbers must be exact 11 alphanumeric characters. One bad character rejects the line.

4. Interest Calculation — Statutory interest accrues from the original entry payment date at 7% annually (non-corp) or 6% (corp), compounded quarterly per 19 U.S.C. 1505.

5. Phase 1 Exclusions — Reconciliation entries, drawback entries, AD/CVD entries, open protest entries, and entries not filed in ACE are excluded from Phase 1.

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Federal Statutory Interest Calculator

Calculated per 19 U.S.C. 1505 and 26 U.S.C. 6621 using IRS quarterly overpayment rates as published in Federal Register Vol. 90 No. 186. Not a simple interest estimate — a statutory refund calculation.

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Federal Statutory Interest Calculator — IEEPA Tariff Refund Overpayment Rates

Statutory interest on IEEPA tariff refunds accrues from the date the original duties were paid through the date CBP issues your refund. This is not optional — it is a legal entitlement under federal statute.

The applicable rates, confirmed across multiple Federal Register publications, are 7% annually for non-corporate importers and 6% annually for corporate importers, compounded quarterly.

For entries paid in April 2025, this means more than a full year of interest accrues on top of your principal refund amount before CBP issues payment.

Source: 19 U.S.C. 1505 · 26 U.S.C. 6621 · Federal Register Vol. 90 No. 186 (September 29, 2025) · Federal Register Document 2026-01175 (January 22, 2026) · Revenue Ruling 2025-22

IEEPA Refund + Statutory Interest Estimate
Principal (Duties Paid)
Statutory Interest Accrued
Total Owed to You
Daily Accrual Rate
Quarters Elapsed

Estimate based on statutory rates per 19 U.S.C. 1505 and 26 U.S.C. 6621, compounded quarterly. Actual amounts depend on entry-level CBP data and the refund process established by the Court of International Trade.

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