The Supreme Court struck down all IEEPA tariffs in February 2026. CBP's refund portal is live and accepting filings now. If your company imported decorative lighting, luminaires, ceiling fans, or components between April 2025 and February 2026, you're likely owed a refund, and the window to claim it has a hard deadline that is already ticking.
This is not a "prepare for what's coming" situation. Companies are filing right now. Entries are aging out of eligibility every day. Here is what you need to know before yours do.
In April 2025, the Trump administration imposed sweeping tariffs on virtually all U.S. imports under the International Emergency Economic Powers Act (IEEPA) — the so-called "Liberation Day" tariffs. The baseline rate was 10%, with country-specific rates reaching 145% on Chinese goods. Lighting fixtures (HTS Chapter 9405) and furniture (HTS Chapter 94) were not granted exemptions.
At peak exposure, companies running China-sourced books faced combined tariffs of up to 104% on top of existing base duties, whether they were importing decorative lighting, upholstered seating, case goods, or components. Lines sourced out of Vietnam, Taiwan, and India weren't spared either. Reciprocal rates hit before the 90-day pause kicked in.
On February 20, 2026, the Supreme Court struck down all IEEPA tariffs as unconstitutional.
On April 20, 2026, CBP launched the CAPE portal — Consolidated Administration and Processing of Entries — to process refunds. The filing window is open now.
The urgency is real: entries that reached final liquidation more than 80 days ago are no longer eligible in Phase 1. Every day that passes, more entries cross that threshold and fall out of scope.
Two parties are authorized to submit refund requests through CAPE:
If your company was the IOR on shipments of decorative lighting, luminaires, ceiling fans, or related components during the IEEPA period, you or your broker can file directly.
A note for rep agencies and manufacturers' reps: you are typically not the IOR — your manufacturer or distributor client is. The refund claim needs to come from whoever was listed on the 7501s. If you're unsure, pull the entry summaries with your broker and confirm before anyone files.
Phase 1 eligibility:
Not eligible in Phase 1:
One important note on protests: If your company previously filed protests specifically to preserve rights to IEEPA refunds, CBP now indicates that withdrawing those protests and refiling through CAPE may result in faster processing — provided the entries fall within CAPE eligibility parameters. Consult your broker before making that decision.
CBP has indicated that additional functionality to cover more complex entry types is planned for future phases.
Three things must be in place before CBP will accept and process a refund:
1. ACE Portal account with an Importer sub-account
The CAPE tool operates entirely within CBP's ACE (Automated Commercial Environment) platform. If you don't have an ACE Portal account with the Importer sub-account type, you'll need to apply before filing. Processing takes a few days.
2. ACH Refund enrollment separate from payment ACH
This is the step most companies miss. CBP will not release your refund until a bank account is enrolled specifically for refund receipt. This is a different enrollment from your standard ACH payment setup. It must be completed inside your ACE account before you file.
3. Your customs entry numbers
You need the 11-character alphanumeric entry numbers for every shipment you're filing. These come from your broker's entry summaries or your 7501s. If you're missing entry data, your broker can pull it — but this takes time, and entries are aging out while you wait.
The filing itself is straightforward once the prerequisites are in place:
The refund includes interest where applicable. Any outstanding CBP debts may be offset against the refund amount.
| Milestone | Timing |
|---|---|
| CAPE portal live | April 20, 2026 ✓ |
| Entries liquidate after CAPE acceptance | ~45 days |
| Refunds issued after acceptance | 60–90 days |
| First refunds expected | June–July 2026 |
Companies filing now — in early May — can realistically receive refunds by July. Companies that wait another 30–45 days will be filing later into a window where more of their entries will have aged out of eligibility.
The CAPE filing itself takes minutes. The preparation is where companies lose time, and where entries expire.
To file accurately, you need to know:
80 days is the filing deadline — the cutoff for submitting a refund claim through CAPE. CBP set this threshold deliberately: they need time to process and reliquidate the entry before day 90.
90 days is the legal deadline — after 90 days from liquidation, an entry reaches "final liquidation" status under U.S. law (19 U.S.C. § 1501) and becomes permanently ineligible for a refund.
That requires matching your SKU-level order history against your customs entry data. If that data lives in spreadsheets, shared drives, or disconnected systems, that cross-reference takes days or weeks. Weeks you may not have.
This applies whether you're a lighting importer tracking luminaires and ceiling fans by HTS 9405 or a furniture company reconciling case goods, upholstery, and components across multiple sourcing countries. The data challenge is the same: who imported what, from where, and when.
Companies running on SuperCat's Sales Portal can move faster at this step. The platform's order history and invoice exports give you a clean line-level view of what was ordered, by whom, and when — organized by date range. That's the starting document your broker needs to match against entry records.
Specifically:
If your order and product data is organized and exportable, filing prep is a few hours, not a few weeks.
This is a moment that exposes whether your sales and order infrastructure is actually working for you. Companies that can pull SKU-level order history by date range in minutes are filing now. Companies still chasing spreadsheets and emailing their broker back and forth are losing eligible entries.
The tariff refund window is temporary. The underlying data problem is not. If your team can't quickly answer "what did we import, from where, and when?" — that gap costs you in refund recovery today and in every future tariff, compliance, or sourcing decision ahead.
IEEPA surcharges (under HTS Chapter 99 codes 9903.01.xx and 9903.02.xx) applied on top of the base duty rates below.
| HTS Code | Description | Base Duty |
|---|---|---|
| 9405.11 | Chandeliers, ceiling/wall — LED | 3.9% |
| 9405.19 | Chandeliers, ceiling/wall — other | 3.9% |
| 9405.21 | Table, desk, floor lamps — LED | 3.9% |
| 9405.29 | Table, desk, floor lamps — other | 3.9% |
| 9405.31 | Lighting strings — LED | 8.0% |
| 9405.39 | Lighting strings — other | 8.0% |
| 9405.50 | Non-electrical luminaires | 2.9% |
| 8414.51 | Ceiling fans | 4.7% |
IEEPA surcharges (under HTS Chapter 99 codes 9903.01.xx and 9903.02.xx) applied on top of the base duty rates below.
| HTS Code | Description | Base Duty |
|---|---|---|
| 9401.30 | Swivel seats with variable height adjustment | Free |
| 9401.40 | Seats other than garden seats, convertible into beds | Free |
| 9401.61 | Upholstered seats with wooden frames — other | Free |
| 9401.69 | Other seats with wooden frames — other | Free |
| 9401.71 | Upholstered seats with metal frames — other | Free |
| 9401.79 | Other seats with metal frames — other | Free |
| 9403.30 | Wooden furniture for offices | Free |
| 9403.40 | Wooden furniture for kitchens | Free |
| 9403.50 | Wooden furniture for bedrooms | Free |
| 9403.60 | Other wooden furniture | Free |
| 9403.70 | Furniture of plastics | Free |
| 9403.81 | Upholstered furniture of other materials | Free |
| 9403.89 | Other furniture of other materials | Free |
A note on furniture duty rates: Most furniture HTS codes (Chapter 94) carry a base duty of Free (0%) for standard trade partners, but IEEPA surcharges still applied on top, meaning companies importing furniture from China, Vietnam, or Taiwan still faced 34–145% in additional duties regardless of the zero base rate.
Note that certain categories carry additional Section 232 tariffs: upholstered wooden furniture seats (9401.61.xx) and kitchen cabinets and vanities (9403.40, 9403.60) were subject to a separate 25% Section 232 duty. If your entries fall into these categories, consult your customs broker before filing. The interaction between Section 232 and IEEPA duties may affect your refund calculation. Verify all duty rates at the USITC HTS lookup tool before filing.
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This guide provides general information only and is not legal, tax, or customs advice. Consult a licensed customs broker or trade attorney before filing. SuperCat Solutions is not affiliated with CBP, ALA, or any government agency. Refund amounts depend on entry-level data and CBP processing. Actual results may vary.