A Tariff Refund Window That Was Closing

An importer recovered $8.5 million in refunded IEEPA tariffs because the claim was assembled and filed inside the eligibility window rather than after it. ROI-AI took this on as a one-off special engagement, outside our core chargeback product. Roy, our AI agent, tracked the IEEPA situation weekly as it developed, extracted entry data from the client's CBP Form 7501 entry summary PDFs at volume, and assembled the CSV declaration the client filed through U.S. Customs and Border Protection's CAPE process. The refund landed because the filing did, on time.

This was a one-off engagement, not our core product

ROI-AI's core product is retailer chargeback and deduction recovery. This IEEPA tariff work was a special, one-off project for a single client. We are publishing it for what it demonstrates about agent adaptability, not because tariff refund recovery is a product we sell.

The situation: a refund window opened, with time limits attached

The refund opportunity exists because the Supreme Court held that IEEPA does not authorize the President to impose tariffs. The Court decided Learning Resources, Inc. v. Trump (No. 24-1287) on February 20, 2026, holding that the International Emergency Economic Powers Act does not authorize the President to impose tariffs (1).

That ruling left CBP to refund duties at extraordinary scale. A Federal Register notice puts tariffs assessed under IEEPA from February 3, 2025 to February 24, 2026 at an estimated $166 billion, with over 53 million entry summaries requiring processing to issue accurate refunds with required interest (2).

To handle that volume, CBP launched CAPE, the Consolidated Administration and Processing of Entries, inside the Automated Commercial Environment (ACE). CAPE streamlines submission and processing of valid refund requests for duties imposed under IEEPA, as authorized by court order or applicable law, and consolidates refunds of IEEPA duties including interest rather than processing them entry by entry (3). CBP deployed CAPE on April 20, 2026 (3).

The time pressure is structural, not administrative. CAPE Phase 1 is limited to certain unliquidated entries and certain entries that are no more than 80 days past liquidation, counted as 80 calendar days including weekends (3, 4). Entries outside that window are not eligible for Phase 1 processing. Assembling a claim quickly is therefore a financial question, not a paperwork question.

What a CAPE claim requires

A CAPE Declaration is a CSV file listing the entry numbers for which an IEEPA duty refund is requested, uploaded through the CAPE tab in the ACE Portal. Each declaration is limited to 9,999 entries, and multiple declarations may be submitted (3, 4, 5). No supporting documentation is required at the time of submission beyond the list of entry numbers (4).

The entry data itself lived in the client's CBP Form 7501 entry summary documents. CBP relies upon Form 7501, the Entry Summary, to determine information such as appraisement, classification, and origin for imported merchandise, and to document the amount of duty and tax paid (6). Those documents were the client's record of which entries carried IEEPA duties and what was paid on them.

What Roy did

1. Tracked the IEEPA situation weekly. Roy monitored IEEPA tariff developments on a weekly cadence as the legal and regulatory position evolved. The refund opportunity and its eligibility window were identified while the client's entries were still inside it.

2. Processed CBP Form 7501 entry summaries at volume. Roy extracted customs entry data from the client's Form 7501 entry summary PDFs and produced the structured, entry-level data needed to identify which entries carried IEEPA duties.

3. Assembled the CAPE CSV declaration. Roy built the CSV declaration in the format CBP's CAPE process requires, listing the eligible entry numbers for submission through the ACE Portal (3, 4).

The outcome

The client recovered $8.5 million in refunded IEEPA tariffs. The filing was made on time, inside the eligibility window. CBP states that valid IEEPA refunds are generally issued within 60 to 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further review (3).

Timing was the whole game. The same entry data, assembled after the window closed, produces no Phase 1 refund at all.

What this proves about agent adaptability

An agent that already reads documents and files structured claims can be pointed at an entirely new regulatory problem without being rebuilt. This engagement required three capabilities in sequence: sustained monitoring of a moving regulatory situation, high-volume extraction from a specific customs document type, and assembly of a submission in an agency-specified format. None of it was tariff-specific engineering. It was the pattern our chargeback work already runs on, which is watch, extract, assemble, and file before a deadline, applied to a different agency and a different document.

Regulatory windows like this one are short and they do not repeat. The constraint is rarely whether the data exists. It is whether anyone can turn it into a filing before the window closes.

Sources

Every source below is a primary government source: the Supreme Court, the Federal Register, or CBP.

1. Supreme Court of the United States, Learning Resources, Inc. v. Trump, No. 24-1287, decided February 20, 2026.
2. Federal Register, "Agency Information Collection Activities; Extension; Court-Ordered Refunds Under the International Emergency Economic Powers Act Worksheet", July 8, 2026.
3. U.S. Customs and Border Protection, "International Emergency Economic Powers Act (IEEPA) Duty Refunds".
4. U.S. Customs and Border Protection, "Consolidated Administration and Processing of Entries (CAPE) Phase 1," Trade Information Notice.
5. U.S. Customs and Border Protection, "ACE Portal: CAPE Declarations" (guidance).
6. U.S. Customs and Border Protection, "CBP Form 7501: Entry Summary".