Amazon FBA Seller Duty Refund: How to Recover IEEPA Tariffs Paid in 2025–2026
By Jeb Singer, Licensed Customs and Trade Attorney, Singer Law Group | Managing Partner, Singer Tariff Recovery
Amazon FBA sellers that paid qualifying IEEPA tariffs between February 4, 2025, and February 24, 2026, may be entitled to an Amazon FBA seller duty refund of those duties plus applicable interest.
The refund is not automatic, and the right filing path depends on where each customs entry stands.
That is where this gets complicated for many FBA sellers.
One seller may have entries spread across several liquidation windows. Some may qualify for CAPE. Others may require a formal protest. Older entries may need a different recovery strategy.
Three terms control the process.
IEEPA, or the International Emergency Economic Powers Act, is the federal statute that was used as authority for the tariffs at issue. Following the U.S. Supreme Court’s February 20, 2026 ruling that IEEPA does not authorize the President to impose tariffs, qualifying importers began working through the refund process.
CAPE, or Consolidated Administration and Processing of Entries, is the process used through the ACE Secure Data Portal for qualifying IEEPA duty refunds.
Importer of Record (IOR) is the entity identified in the customs entry records as responsible for the import. The IOR is central to determining who may claim the refund.
For an Amazon FBA seller, the practical question is not simply whether IEEPA duties were paid.
Who was the Importer of Record?
Which entries included IEEPA duties?
Have those entries been liquidated?
If they have, when?
Those answers determine what comes next.
Your liquidation date determines your door. The sellers that recover are the ones that sort their entries first and file second.
What Is the Amazon FBA Seller IEEPA Duty Refund?
Amazon FBA sellers that paid qualifying IEEPA tariffs during the affected period may be able to recover those duties plus applicable interest following the Supreme Court’s February 2026 decision.
But no refund should be assumed.
The importer still needs to identify the affected entries, confirm eligibility, determine where each entry stands in the customs process, and use the appropriate recovery procedure.
The Supreme Court’s decision addressed the President’s authority to impose tariffs under IEEPA. For importers, the ruling created a practical customs question: how do you identify recoverable duties and get those entries into the right refund process?
That starts with the entry history.
For the full background on IEEPA tariffs, the legal history matters, but an Amazon seller trying to recover duties needs to know what happened on its own entries.
The total amount paid across the market doesn't tell you what your business may recover.
Your customs records do.
Pull the entries. Identify the IEEPA duties that were paid. Check the liquidation dates. Then determine which filing path applies.
Am I Eligible? Confirming Your Importer of Record Status
The Importer of Record is one of the first things an Amazon FBA seller should confirm before working through a potential IEEPA refund.
Pull CBP Form 7501 for the entries you are reviewing and confirm the Importer of Record information against the company’s customs records.
Do not assume your company was the IOR simply because it purchased the merchandise or ultimately sold it through Amazon.
This can become especially important for sellers that imported under DDP, or Delivered Duty Paid, terms. Depending on how the transaction and customs entry were structured, a supplier, freight forwarder, or another party may appear in the import records.
If someone else appears as the Importer of Record, do not assume the refund belongs to your company without reviewing the entry records and the arrangement behind them.
For a complete breakdown of IEEPA refund eligibility rules, review the eligibility requirements before building the refund claim.
The basic questions are straightforward:
Who appears as the Importer of Record?
Does that information match the company’s customs records?
Who paid the duties?
Which entity’s importer number appears on the entries?
Once those questions are answered, the seller has a much clearer picture of whether it
can pursue the refund.
Amazon Global Logistics Users: You Are Still the IOR
Using Amazon Global Logistics does not automatically mean Amazon is the Importer of Record for your entries.
Amazon Customs and Trade may serve as the customs broker while the FBA seller remains the Importer of Record.
That distinction matters.
A customs broker handles customs filings on behalf of the importer. The broker’s involvement does not, by itself, change which entity appears as the Importer of Record.
If you used Amazon Global Logistics, check the customs documents rather than assuming you qualify or don't qualify based on the shipping program alone.
Pull the CBP Form 7501.
Confirm the Importer of Record.
Then determine whether your company is the party associated with the entries and duties being reviewed.
For FBA sellers, that is a much safer starting point than relying on how the shipment appeared inside the Amazon logistics system.
What Are the Three Refund Pathways Based on Entry Liquidation Date?
The correct refund pathway for each customs entry depends on its liquidation date. Some entries may go through CAPE, others may require a formal protest, and older entries may need evaluation for Court of International Trade litigation.
That is why Amazon FBA sellers should sort their entries by liquidation status before filing anything.
Entry liquidation is CBP’s final accounting of the duties owed on a customs entry. Once an entry liquidates, the date becomes important because it affects which refund options may still be available.
For an FBA seller with dozens or hundreds of shipments, there may not be one refund path for the entire import history.
Each entry must be reviewed separately.
CAPE Filing: Unliquidated Entries and Entries Within 80 Days
CAPE is used for qualifying entries that fall within the applicable CAPE filing window.
The process runs through the ACE Secure Data Portal and allows importers to submit qualifying entry information electronically.
For an Amazon FBA seller, the work starts before the filing.
Pull the entry summary numbers. Confirm the IEEPA duties that were paid. Check the liquidation status. Make sure the Importer of Record information is correct.
Then determine which entries belong in CAPE.
For sellers with a large number of qualifying entries, organizing the records first can make the filing process much more manageable.
Formal Protest: Entries Liquidated 80 to 180 Days Ago
Once an entry has liquidated and falls outside the applicable CAPE window, a formal customs protest may be the appropriate administrative path.
The important deadline is 180 days from liquidation.
You need to track the 180-day customs protest deadline entry by entry because each
customs entry can have a different liquidation date.
This is where FBA sellers can get into trouble.
If a seller has entries spread across several months, some may have plenty of time left while others may be nearing the protest deadline.
Do not wait until every entry has been reviewed before checking the dates.
Start with the liquidation report. Identify the entries with the closest deadlines first. Then determine what to file for each one.
Court of International Trade Lawsuit: Entries Over 180 Days
Entries that are already outside the administrative protest period require a different analysis.
Depending on the entry and procedural history, you may need to consider litigation in the U.S. Court of International Trade.
The Court of International Trade litigation pathway is different from filing through CAPE or submitting a customs protest. It has its own jurisdictional and procedural requirements,
which you need to review based on the entries involved.
For an Amazon FBA seller with older entries, the first step is to identify exactly which entries have passed the 180-day protest period.
Do not assume an older entry is recoverable.
Do not assume it is lost either.
Look at the entry, the liquidation date, what was paid, and what happened procedurally.
Then determine whether a litigation path is available.
Most Amazon sellers with a meaningful import history will not necessarily have every entry in the same bucket.
Some may still be unliquidated.
Some may fall within the CAPE process.
Some may have a protest deadline running.
Some may already be outside the administrative window.
Sort the entries first.
Then file through the path that applies to each one.
How Do Amazon FBA Sellers File for a Duty Refund via CAPE?
Filing a CAPE Declaration through the ACE Secure Data Portal starts with organizing the importer’s records, setting up the appropriate ACE access, confirming refund information, and preparing the entry data for submission.
The process has seven steps.
Step 1: Pull Your Duties Paid Record. Request a per-entry list of IEEPA duties paid between
February 4, 2025, and February 24, 2026 from your customs broker.
This is often where FBA sellers run into the first problem.
Many sellers know their total landed costs, but they don't have the individual customs entry information behind those numbers. Duties, freight, brokerage charges, and other costs may all appear together in an inventory or accounting system.
That is not enough for a CAPE filing.
You need the individual entry summary numbers for the shipments being reviewed. If you used more than one customs broker during the period, you may need to collect records from
several places before you have the full entry history.
Do that work before you start building the filing.
Step 2: Confirm IOR Status on CBP Form 7501. Check the Importer of Record information on the entries before proceeding.
Don't assume your Amazon business was the IOR just because it purchased or sold the merchandise.
Confirm it in the customs records.
Review the IOR information against the company’s importer records so you know which entity is tied to the entries and any potential refund.
Step 3: Create an ACE Portal Top Account. If the company does not already have the necessary ACE Portal access, set up the account before the CAPE filing can move forward.
Have the company’s Importer Record Number, legal business name, and the email associated with its customs records available when setting up the account.
Make sure the information being used matches the company’s CBP records.
A mismatch at the account stage can slow down everything that follows.
Step 4: Complete Two-Factor Authentication Within the Required Window. Once the ACE account setup begins, complete the authentication steps when CBP sends them.
Do not leave account setup half finished while working on the entry list.
If CBP provides a limited window to complete an authentication step, handle it when the notice arrives so account access doesn't delay the filing.
Step 5: Enroll a U.S. Bank Account for ACH Refunds. The refund information in ACE also needs to be set up correctly.
Confirm that the bank account belongs to the appropriate business and that the information entered in the portal is accurate.
Treat the banking information as sensitive company information. Enter it through the appropriate ACE process and do not provide it to an unsolicited third party offering to handle
a refund.
Step 6: Upload Your CAPE Declaration CSV. Once the entries have been reviewed and the account is ready, prepare the CAPE Declaration using the required entry information.
For an Amazon FBA seller with a large import history, this is where the work done in Step 1 matters.
The entry summary numbers need to match the entries being claimed. The Importer of
Record information needs to be correct. The entries need to belong in the CAPE process.
Do not build the CSV first and investigate the entries afterward.
Review first. File second.
For a detailed walkthrough of how to file through CBP’s CAPE portal, Singer Tariff Recovery explains the filing process and the records importers should have ready before they begin.
Step 7: Monitor Your Claim Status. Submitting the declaration does not mean the work is finished.
After filing, monitor the claim and keep the supporting entry records organized.
For sellers with a large number of entries, keep track of what was submitted, which entries were included in each filing, what has been processed, and what remains outstanding.
If an entry does not move as expected, go back to the records.
Check the entry number.
Check the liquidation status.
Check what duties were paid.
Check whether the entry was placed in the correct filing path.
For Amazon FBA sellers, CAPE is much easier to manage when you organize the customs records before filing begins.
The portal is only one part of the process.
The entry history is what tells you what to put into it.
Common Mistakes and Myths That Cost FBA Sellers Their Refund
Amazon FBA sellers should not assume the IEEPA duty refund will happen automatically.
You need to review the entries, identify the correct filing path, and track any applicable deadlines.
The mistakes below can create problems before the refund process even gets started.
Assume the refund is automatic. Don't assume a refund will arrive just because your business paid IEEPA duties. Start with the customs records, identify the affected entries, and determine what to file for each one.
File CAPE for entries that do not belong in the CAPE process. An entry’s liquidation status matters. Filing an entry through the wrong process can cost valuable time while another deadline continues to run. Sort the entries by liquidation date before deciding which filing path applies.
Assume Amazon Global Logistics disqualifies you as the IOR. Using Amazon Global Logistics does not automatically mean Amazon is the Importer of Record. The customs broker and the Importer of Record are not necessarily the same party. Check the actual entry documents and confirm who appears as the IOR before deciding whether your company may pursue the refund.
Not knowing your entry summary numbers. Many FBA sellers know what they paid in landed costs but do not have the individual entry summary numbers behind those totals. If duties, freight, brokerage charges, and other costs are combined in your accounting or inventory system, you may need to go back to your customs broker and reconstruct the entry history. Gather those records before you try to file.
Miss the 180-day protest window while waiting. If an entry is approaching the applicable protest deadline, waiting for another refund option can create a much bigger problem. Check the liquidation dates first and identify the entries with deadlines that need immediate attention.
The common thread is simple.
Do not start with the filing.
Start with the entries.
For an Amazon FBA seller with shipments moving through different brokers, suppliers, and logistics programs, customs history may not sit neatly in one place. It may take some work to
put the records together.
That work should happen before you miss deadlines.
Protecting Your Business From CAPE Refund Fraud
Amazon FBA sellers should also watch for unsolicited emails, phone calls, and social media messages offering to recover IEEPA duties.
A tariff refund can involve sensitive business information, including ACE account information, customs records, Importer of Record information, banking details, and company identification information.
Do not provide that information simply because someone claims they can recover a refund for you.
Know who you are working with.
Understand what they are asking for.
Know why they need the information.
And make sure you understand what will actually be filed on behalf of your company.
Be especially careful with ACE login credentials and banking information. Treat them the same way you would treat other sensitive financial and business account information.
A legitimate refund process should begin with the customs entries and the company’s filing options, not with an unsolicited request for sensitive account credentials.
For Amazon FBA sellers, the safest approach is the same one that applies throughout the refund process:
Verify first.
Then act.
When Should an Amazon FBA Seller Work With a Tariff Recovery Attorney?
FBA sellers with older liquidated entries, complicated Importer of Record questions, or high-value refund claims should consider speaking with a customs attorney before an applicable protest or litigation deadline passes.
For a straightforward group of qualifying entries, the CAPE process may be relatively manageable.
But many FBA sellers do not have one clean group of entries.
They may have imported through multiple customs brokers. Some entries may still be open while others have liquidated. Some may be approaching the 180-day protest deadline.
Others may involve questions about who was listed as the Importer of Record.
That is when you need to look at the entry history as a whole.
Singer Tariff Recovery, the tariff recovery practice co-founded by Jeb Singer, Managing
Partner of Singer Law Group, Benjamin Weiss, and Pamela Gold, works with U.S. importers on IEEPA tariff recovery matters involving ACE and CAPE review, customs protests, and
Court of International Trade litigation.
The process starts with the records.
Which entries included IEEPA duties?
Who was the Importer of Record?
When did each entry liquidate?
Which entries may still qualify for CAPE?
Which entries have a protest deadline running?
Which older entries need review for another potential recovery path?
Answer those questions before deciding what to file.
For Amazon FBA sellers with a large number of entries, the goal is to separate the import history into the right groups and deal with each one based on its actual status.
There may also be situations where an importer is concerned about how long the refund process could take and what that timing means for cash flow. Where advance funding is available, terms and availability depend on the claim and the importer's circumstances.
That decision should start with the numbers.
How much was actually paid in qualifying duties?
How much of the potential claim has been supported by the customs records?
Which entries are ready to move forward?
What deadlines are already running?
Once you have those answers, the importer is better positioned to decide how to proceed.
To discuss your specific entry history and determine which recovery pathway may apply, schedule a free consultation with Singer Tariff Recovery.
You can also reach the firm directly at (917) 905-8280.
Frequently Asked Questions
Who is eligible for an Amazon FBA seller duty refund?
First, determine whether your business is the Importer of Record for the entries at issue.
Check the Importer of Record information on CBP Form 7501 and compare it with the company’s customs records. Do not assume your company was the IOR simply because it purchased the merchandise, paid a supplier, or sold the goods through Amazon.
This is especially important for sellers that imported under DDP terms, where another party may appear in the customs records.
Amazon FBA sellers using Amazon Global Logistics should also check the actual entry documents. Using Amazon Global Logistics does not automatically mean Amazon was the
Importer of Record. Amazon Customs and Trade may act as the customs broker while the seller remains the IOR.
The customs records should answer that question before the refund process begins.
What IEEPA duties are covered and for what time period?
The refund process addressed in this article concerns qualifying IEEPA duties imposed during the affected 2025 and 2026 period.
That includes IEEPA duties connected to the tariff measures that began in February 2025 and the reciprocal tariff measures that followed in April 2025, through the end of the affected period in February 2026.
Whether a particular entry qualifies depends on what duties were actually assessed and paid on that entry.
Do not assume every customs duty paid during that period qualifies for an IEEPA refund.
An entry may contain different types of duties, including duties imposed under other tariff authorities. Separate those amounts when reviewing the potential claim.
Start with the entry data and identify the specific tariff provisions and duty amounts that were charged.
How do I know whether to use CAPE, a formal protest, or a Court of International Trade lawsuit?
Start with the liquidation status of each customs entry.
Qualifying entries that fall within the applicable CAPE process may be handled through
CAPE. Entries that are outside that process but still within the administrative protest period may require a formal customs protest.
Once an entry is outside the administrative protest period, you must evaluate the available options separately, including whether Court of International Trade litigation is available based on the entry’s procedural history and applicable legal requirements.
For an Amazon FBA seller with entries spread across several months, there may be more than one answer.
One group of entries may belong in CAPE.
Another may have a protest deadline approaching.
Older entries may require a different review.
That is why the first step is to sort the entries by status and liquidation date.
What is the CAPE portal and how does an Amazon FBA seller access it?
CAPE, or Consolidated Administration and Processing of Entries, is the process used through the ACE Secure Data Portal for qualifying IEEPA duty refunds.
An Amazon FBA seller needs the appropriate ACE account access and the customs entry information required for the filing.
Before starting, gather the company’s Importer of Record information, legal business information, entry summary numbers, and the records showing the IEEPA duties paid.
The company should also make sure its ACE account and refund information are set up correctly.
Once the account is ready, you can prepare qualifying entry information for submission through the CAPE process.
For sellers with a large number of shipments, don't start with the portal.
Begin with the records.
The filing becomes much easier once you know which entries actually belong in it.
Can Amazon FBA sellers using Amazon Global Logistics get an IEEPA duty refund?
Using Amazon Global Logistics does not automatically prevent an FBA seller from pursuing
an IEEPA duty refund.
The important question is who appears as the Importer of Record on the customs entries.
Amazon Customs and Trade may act as the customs broker without replacing the seller as the Importer of Record. The broker and the IOR perform different roles.
If you used Amazon Global Logistics, pull the customs documents and confirm the IOR information before deciding whether your company qualifies.
Don't self-select out of the refund process just because Amazon handled the logistics or customs brokerage.
Check the entry first.
What happens if my customs entries were liquidated more than 180 days ago?
Entries outside the administrative protest period require a different review.
Depending on their status and procedural history, CAPE and a timely customs protest may
no longer be available for those entries.
That does not mean an importer should automatically assume it can still recover the duties through litigation. It also does not mean the entries should automatically be written off.
Review the entry history to determine whether a Court of International Trade claim or another available recovery path may apply.
For an Amazon FBA seller with older entries, gather the liquidation dates, entry summaries, duty information, and any prior filings or protests connected with those entries.
Then determine what options remain before taking the next step.
About the Author
Jeb Singer is the Managing Partner of Singer Law Group and a co-founder of Singer Tariff Recovery. He was admitted to practice in New York in 2009 and founded J. Singer Law Group in November 2014.
Through Singer Tariff Recovery, Jeb works with U.S. importers to review potential tariff recovery opportunities. That work begins with the customs records, including Importer of Record information, ACE data, entry summaries, liquidation status, duties paid, and applicable protest deadlines.
For Amazon FBA sellers, the same approach applies. Before deciding how to pursue a refund, determine who the Importer of Record is, which entries included qualifying IEEPA duties, where those entries stand in the liquidation process, and which recovery path may still be available.
The goal is to understand the entry history first and make filing decisions based on what the records actually show.
To discuss your Amazon FBA import history and potential IEEPA duty refund options, contact Singer Tariff Recovery at (917) 905-8280.
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