IEEPA Duty Recovery Playbook 2026
A comprehensive playbook for US importers pursuing duty recovery following the February 2026 Supreme Court ruling on IEEPA tariff authority. Current as of Q2 2026.
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Who This Guide Is For
This playbook is designed for trade compliance professionals and finance leaders at US-importing organisations navigating the post-ruling recovery landscape.
Compliance Officers
Managing IEEPA recovery across multiple brokers and entry types
CFOs & Controllers
Quantifying recoverable duties and understanding personal liability exposure
Customs Brokers
Advising importer clients on CAPE eligibility and filing strategy
What\u2019s Inside
13 chapters covering every aspect of IEEPA duty recovery \u2014 from the Supreme Court ruling through to a practical readiness checklist.
The February 2026 Supreme Court Ruling Explained
Key holdings, what the Court struck down, and what remains in force.
What is IEEPA?
Historical context, the 2025 expansion, and IEEPA vs. Section 232/301.
Which Tariffs Are Eligible for Refund
Eligibility analysis by statutory authority and executive order.
The CAPE Portal Process
Architecture, access requirements, and claim submission data.
Phase 1 Eligibility and Timeline
Eligibility criteria, filing windows, and key deadlines.
Documentation Requirements
Mandatory documentation packages and claim submission data.
Compliance Considerations
19 USC §1641 obligations, penalty exposure, and origin verification.
Risk Mitigation During Duty Recovery
Avoiding CBP scrutiny triggers and protecting your compliance record.
Step-by-Step Recovery Workflow
Complete workflow from entry audit to refund receipt.
Case Study Examples
Real recovery scenarios across electronics, industrial, and UK exporters.
Why Licensed Broker Oversight Matters
Regulatory requirements and the independent auditor advantage.
How mycustomsinfo.com Manages IEEPA Recovery
Platform capabilities, automation, and compliance safeguards.
Recovery Readiness Checklist
A practical checklist to assess your organisation’s readiness.
Key Highlights
Supreme Court Ruling Analysis
Detailed breakdown of what the 6–3 ruling means for importers, which tariffs are voided, and what remains enforceable.
CAPE Portal Step-by-Step
Complete guide to the CBP’s Consolidated Administration and Processing of Entries system for filing recovery claims.
Phase 1 Eligibility & Deadlines
Understand which entries qualify for Phase 1, filing windows, and what happens if you miss the deadline.
Compliance Risk Mitigation
How to file CAPE claims without triggering CBP scrutiny on your broader import programme.
Licensed Broker Oversight
Why every CAPE Declaration should be reviewed by a 19 USC §1641 licensed professional.
Recovery Readiness Checklist
A practical checklist to assess your organisation’s preparedness before filing.
Related Guides
IEEPA recovery is one piece of the compliance puzzle. These complementary guides cover the broader landscape.
Multi-Jurisdictional Customs Compliance Guide
IEEPA recovery opportunities are best maximised when viewed alongside your broader compliance posture across UK, EU, US, and APAC.
Download free guideCBAM Compliance Guide 2026
Understanding how US tariff changes interact with EU carbon border adjustments is increasingly critical for multi-jurisdictional importers.
Download free guideReady to Assess Your IEEPA Recovery Potential?
Our team can review your import history and identify recoverable IEEPA duties within 48 hours of data submission.