IEEPA Tariff Refunds: What Lighting and Furniture Companies Need to Do Now

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.

What Happened and Why It Matters

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.

Who Can File

Two parties are authorized to submit refund requests through CAPE:

• The Importer of Record (IOR) — the company listed on the customs entry as the importer
• A licensed customs broker — authorized to act on the importer's behalf

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.

What Qualifies (and What Doesn't)

Phase 1 eligibility:

• Unliquidated entries (still open)
• Entries liquidated within the last 80 days

Not eligible in Phase 1:

• Entries with antidumping or countervailing duties (AD/CVD)
• Entries tied to duty drawback or reconciliation programs
• Entries currently under protest or review
• Entries that have reached final liquidation (90+ days ago)

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.

What You Need Before You File

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.

How the CAPE Process Works

The filing itself is straightforward once the prerequisites are in place:

1. Log into ACE and navigate to the CAPE tab
2. Compile your entry numbers into a CSV file — just entry numbers, no other fields
3. Upload the CSV (maximum 9,999 entries per file; submit additional files if you exceed that)
4. CBP runs a two-stage validation: file-level format check, then entry-level eligibility screening
5. Ineligible entries are automatically filtered out — you don't need to pre-sort them
6. CBP removes the IEEPA tariff lines from qualifying entries, recalculates total duties as if those tariffs were never applied, and refunds the difference
7. Refund is issued as a single consolidated ACH payment per importer

The refund includes interest where applicable. Any outstanding CBP debts may be offset against the refund amount.

Expected Timeline for Refunds 

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 Data Problem Most Companies Haven't Solved Yet

The CAPE filing itself takes minutes. The preparation is where companies lose time, and where entries expire.

To file accurately, you need to know:

• Which SKUs you imported during the IEEPA period (April 2025 – February 2026)
• Which entries those shipments correspond to (from your customs broker)
• Which entries are still within the 80-day eligibility window

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.

Where SuperCat customers have an advantage

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:

• Sales Portal reports (Product Detail, Monthly, Sales Summary) export to CSV/XLSX and can be filtered to the IEEPA period
• Invoice management lets you pull every invoice for any date range — useful for identifying which shipments are candidates for refund
• Customer purchase export gives you a per-customer, per-SKU breakdown your broker can match against import entries
• Product custom fields in the admin console can be used to tag products with HTS codes or country of origin going forward — so the next tariff event doesn't require the same scramble

If your order and product data is organized and exportable, filing prep is a few hours, not a few weeks.

If your data isn't organized yet

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.

Lighting HTS Code Reference

IEEPA surcharges (under HTS Chapter 99 codes 9903.01.xx and 9903.02.xx) applied on top of the base duty rates below.

Furniture HTS Code Reference

IEEPA surcharges (under HTS Chapter 99 codes 9903.01.xx and 9903.02.xx) applied on top of the base duty rates below.

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.

Official Sources

Government / CBP

• CBP IEEPA Duty Refunds — CAPE process, FAQ, eligibility
• ACE Portal Application — how to create an ACE account
• USITC Harmonized Tariff Schedule — official HTS lookup
• CBP technical questions: IEEPARefunds@cbp.dhs.gov

Legal Analysis

• ArentFox Schiff — CAPE Process Walkthrough
• Troutman Pepper — Filing Mechanics and Phase 1 Scope
• V. Alexander — Broker Perspective on CSMS Guidance

Industry

• American Lighting Association
• inside.lighting — Tariff Impact Coverage

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.