IEEPA Tariff Refund Status

Last Updated: May 15, 2026

This document is intended for Spaceship customers and operations staff to understand the current status of IEEPA tariff refunds and what action (if any) is required.

Background: Why Are Refunds Happening?

On February 20, 2026, the US Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that all IEEPA-based tariffs were unconstitutional and unlawfully imposed. This voided tariffs that had been applied to China/Hong Kong goods from February 4, 2025 through February 23, 2026 — rates that ranged from +10% to a peak of +145% on top of existing duties.

As a result, CBP (US Customs and Border Protection) opened the CAPE refund system on April 20, 2026, and began issuing ACH refund payments to eligible importers from May 11–12, 2026 onward.

Combined Tariff Rate History (IEEPA-Stack on China/HK)

The table below captures the full IEEPA tariff stack applied to China/Hong Kong-origin goods from February 2025 through the Supreme Court ruling, and the Section 122 replacement thereafter.

Important: Both the Fentanyl and Reciprocal IEEPA tariffs are fully additive — they stack on top of each other, as confirmed by CBP official guidance, WilmerHale, and the US-China Business Council. These IEEPA rates are also additive on top of Section 301 (7.5%–145%), Section 232 (25–50% on metals), and MFN base rates — all of which remain fully in force as of May 2026. 

How the Stack Works 

⚠️ Spaceship Refund Pass-Through Policy

🔄 Spaceship Is Currently Clarifying Details with Couriers

Spaceship has reached out to FedEx and UPS to clarify the following key questions regarding the refund process:

• Whether UPS will refund duties directly to Spaceship as the account holder, or to the consignee who originally paid

• Whether the refund receiver needs to set up ACH banking in the ACE Portal, or if UPS/FedEx handles the CBP ACH step and remits to Spaceship separately via its own billing system

• Which entry phases and timelines apply to Spaceship's account, and how UPS will notify Spaceship when refunds are received

We are awaiting couriers' written response. Further updates will be shared with customers once confirmed.

Section 1: FedEx — Refund Status (May 2026)

Current Status

FedEx began submitting CAPE Declarations to CBP on April 20, 2026 — the first day the portal opened — on behalf of all customers who originally bore the IEEPA charges for FedEx-brokered shipments. CBP has started issuing IEEPA tariff refunds on a rolling basis from May 11, 2026.​

Official FedEx FAQ (Latest Communication) 

Key Conditions for FedEx Refunds

• FedEx must have been the customs broker on the shipment (not just the carrier)​

• Entry must fall within Phase 1 scope: entries from January 30, 2026 onward, or unliquidated entries​

• No active protest, AD/CVD review, or drawback flag on the entry​

• No customer action required for Phase 1 entries — FedEx handles all CAPE filings on the customer's behalf

What FedEx Cannot Do

FedEx has explicitly stated it cannot provide entry-level reports or estimates of refund amounts because duty billing records reside outside its entry system. This means Spaceship also cannot pre-calculate or pre-commit to specific refund amounts for customers.​

Section 2: UPS — Refund Status (May 2026)

Current Status

UPS processed approximately 16 million IEEPA-related entries and remitted over $5 billion in IEEPA tariffs to the US Treasury on customers' behalf. UPS began filing Phase 1 CAPE Declarations on April 20, 2026, and CBP has started issuing refunds from May 11–12, 2026.

UPS has confirmed: refunds to customers can only be issued after UPS receives the funds from CBP.​

Key Conditions for UPS Refunds

UPS's role as Importer of Record (IOR) — and therefore its ability to file automatically — depends on shipment value:​

For Formal Entries (over $2,500), the customer is the Importer of Record and must file their own CAPE Declaration through CBP's ACE Portal. See Section 3 for the self-filing guide.

Phase Coverage

⚠️ Shipments from the peak tariff period (April–November 2025, up to 145% IEEPA stack) are in Phase 2+ with no confirmed timeline. Importers should consider filing a protest within 180 days of liquidation to preserve rights for these entries.

No Customer Action Needed (if UPS is IOR)

For de minimis and informal entries where UPS is IOR, UPS automatically files and passes refunds through — customers just need to ensure ACH banking is enrolled in the ACE Portal (CBP no longer issues paper checks).

Section 3: Self-Filing Guide — When You Are the IOR (Formal Entry, Over $2,500)

If UPS was not the Importer of Record on your shipment (Formal Entry, value over $2,500), you must file your own CAPE Declaration directly through CBP's ACE Portal.

Pre-Filing Checklist

•  ACE Portal account with Importer sub-account access (ace.cbp.dhs.gov)

•  ACH refund bank account enrolled in ACE — this is separate from payment ACH; having duty-payment ACH is NOT sufficient

•  Complete list of entry numbers from CBP Form 7501 (Block 1)

•  Company email matching your CBP Form 5106 record​

•  No active protests on entries you plan to submit — entries under protest are excluded from Phase 1​

Filing Steps (Summary)

1. Log in to ACE Portal → Importer sub-account → enrol ACH Refund bank account under the ACH Refund Authorization tab

2. Download the CAPE CSV template from the CAPE tab: ACEP_CapeEntryNumberUploadTemplate.csv — single column, entry numbers only, max 9,999 per file

3. Upload the file via CAPE tab → check the legal authority acknowledgment box to enable submission​

4. Monitor status via ACE report ES-022 (CAPE Entry Summary) and REV-603 (Trade Refund Report)​

5. Refunds are issued as consolidated ACH lump sum per IOR — typically 60–90 days after declaration acceptance

⚠️ CAPE Declarations cannot be amended after acceptance. Ensure all entry numbers are correct before submitting.​

Section 4: Spaceship Air — Refund NOT Applicable

Service Overview

Spaceship Air – Economy is an economy air service, with the US listed as a "Tax Inclusive" destination — meaning import duties and taxes are pre-collected and bundled into the service rate at time of shipment.

Why IEEPA Refunds Do Not Apply

🚫 IEEPA tariff refunds are NOT applicable for shipments sent via Spaceship Air – Economy. No refund will be issued for Spaceship Air shipments regardless of the outcome of the CBP refund process.

Quick Reference: Which Service Is Eligible?

Key Risk: Government Appeal Deadline June 6, 2026

The US Department of Justice has until June 6, 2026 to appeal the Court of International Trade's refund order. If the government appeals and obtains a stay from the Federal Circuit, all future CAPE refund disbursements could be frozen. Refunds already paid out would not be reversed, but Phase 2+ and pending Phase 1 entries could be significantly delayed. Spaceship will monitor this deadline and communicate any changes to affected customers.