What happened with the IEEPA Tariffs?
On 20 February 2026, the US Supreme Court ruled that the tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful. US Customs and Border Protection (CBP) was instructed to refund those tariffs, plus interest, to whoever was the Importer of Record (IOR) on the shipment. The CBP launched CAPE (Consolidated Administration and Processing of Entries) on April 20, 2026 as the system for processing refund filings on tariffs that may be returned.
Commercial carrier shipments: Filing must go through the importer of record (IOR). See below for more information on this.
Postal shipments: Postal shipments cannot currently be refunded through CAPE. CBP has not yet announced what process merchants will use to claim refunds on postal IEEPA duties.
Who is the Importer of Record on my shipments?
Depending on your cross-border setup, the IOR can be:
your carrier's brokerage (DHL, FedEx, UPS, etc.) — the most common case for cross-border ecommerce
you, the merchant, if you hold your own US customs bond and self-file
in a small number of cases, the consumer — where the shipment is valued over $2,500 and they have completed a CBP Form 5106
Am I (the merchant) the Importer of Record?
You are the Importer of Record on your US-bound shipments if all three of the following are true:
you have a US EIN (Employer Identification Number)
you maintain a US Customs Bond in your own name
you have contracted with a customs broker accordingly
If any of those is missing, your carrier's brokerage is almost certainly the IOR on your entries, and the refund path runs through them rather than through you.
Refund entitlement attaches to whoever was named IOR on the entry, not to whoever actually paid the tariff. So if you shipped DDP and absorbed the IEEPA cost in your pricing, but your carrier was still named IOR, then the filing authority sits with them.
⚠️ Note: This refund only covers the IEEPA-based tariffs — the 10%+ baseline "reciprocal" tariff, the country-specific elevated rates, and the 25% Canada/Mexico tariff. It does not cover Section 301 China tariffs, Section 232 steel/aluminium/auto tariffs, antidumping/countervailing duties, or the Section 122 tariff (now deprecated) that replaced IEEPA from 24 February to 24 July 2026.
What to do next, based on your IOR status:
If DHL Express was your Importer of Record: DHL is already filing on your behalf and has started issuing IEEPA credits directly to DHL accounts, in phases. You don't need to do anything — DHL will refund you automatically as CBP processes each refund. Only the IEEPA portion is credited; other duties still apply. Learn more about DHL's filing process here.
If FedEx was your Importer of Record: Swap now has direct access to FedEx's IEEPA refund portal and our Cross-Border team is actively reconciling eligible shipments on your behalf. Because the portal only accepts 100 entries per submission and there are several hundred thousand shipments to work through, this is being processed in batches. We will contact you when your refund is ready to be credited.
If UPS was your Importer of Record: UPS is filing directly for shipments on your behalf, so no action is needed from you and there's no need to contact them. Bear in mind UPS offsets any refund against past-due invoices on your account before disbursing the remainder, and won't refund administrative, brokerage or disbursement fees. You can check a specific shipment's eligibility using UPS's own lookup tool.
If you were your own Importer of Record: you'll need to file directly with CBP through their ACE portal, or via your own customs broker. Swap can help provide the underlying shipment data to support that claim, but cannot file it on your behalf in this scenario.
If DHL Ecommerce, a consolidator, or any other party not mentioned in this article acted as your IOR on Swap Global shipments, please contact [email protected] or your Account Manager.
If you shipped using Swap Clear:
Swap Clear shipments are eligible for the same FedEx refund process as Swap Global in the large majority of cases.
Where FedEx was IOR (the large majority): Swap is reconciling your claim through FedEx's IEEPA reclamation portal, the same process as Swap Global. The refund flows to Swap and is reconciled back to you.
Where your US entity was named IOR — which happens only where a specific self-filing arrangement was set up, with your own customs bond posted — you'll need to file directly through your own broker or ACE access. Swap has no standing to claim on entries where it wasn't the named importer.
If you're on Swap Clear and unsure which applies to your account, contact your account manager.
Timeline — what to expect
This is a genuine, active process, but it is not instant, and CBP — not Swap or the carrier — controls the pace. Once a claim is submitted:
CBP is processing refunds in phases. Phase 1 (entries closest to liquidation) has been paying out since 11 May 2026. Phase 2 (entries flagged for reconciliation) opened 29 June 2026 and are actively being paid out now.
Typical processing time from submission to funds landing is 1–5 months, but this is subject to change depending on the pace of the CBP.
Refunds arrive as a direct payment to whoever was the Importer of Record (the carrier, in most cases) — not directly to you as the merchant. Where Swap or the carrier receives the funds, a reconciliation step is still needed to match refunds back to the correct merchant, since these come through as many individual payments rather than one lump sum.
We'll provide updates as batches are submitted and as refunds start to land — but please treat any timeline as an estimate, not a commitment, since it depends on CBP's processing speed.
You can read the CBP's official guidance about applying for an ACE portal account and filing a CAPE declaration here.
Frequently asked questions
Has my refund already been approved?
We can confirm whether your shipment has been submitted for a refund. We cannot confirm CBP has approved or paid it until that actually happens — CBP, not Swap, makes that determination.
Why hasn't everything been refunded yet?
CBP is working through this in phases and has not yet completed Phase 2 for all eligible shipments. Many shipments are still waiting on CBP, not on Swap or the carrier.
Will the new 10% tariff also be refunded?
No. That was a separate charge (Section 122), introduced after the IEEPA tariffs were struck down, and it was never part of this refund. Section 122 has since been deprecated — it expired on 24 July 2026 and was replaced by Section 301 duties of 10%–12.5% on imports from around 60 economies. Those are also separate from IEEPA and are not refundable under this process.
How much will I get back?
We can't quote a figure until CBP has processed and paid the specific claim. Total value depends on your shipment volume and the tariffs originally charged.
What do I need to do?
If DHL, FedEx or UPS was your Importer of Record, nothing — the filing is being handled for you, either by Swap (FedEx) or by the carrier directly (DHL, UPS). If you were your own Importer of Record, you'll need to file directly with CBP or your broker; contact your Swap account manager if you'd like help pulling the underlying shipment data.