Are Section 301 tariffs refundable under this ruling?

No. Section 301 tariffs are imposed under the Trade Act of 1974 to address unfair trade practices, a separate legal authority from IEEPA. The Learning Resources ruling does not affect Section 301 tariffs, so they are not refundable through the CAPE process.

Can one shipment have both refundable and non-refundable tariffs?

Yes, and this is the most common source of confusion. A single entry can carry both an IEEPA tariff line item and a Section 301 (or 232, 201, or AD/CVD) line item at the same time. Only the IEEPA-based portion is potentially refundable under this ruling, so eligibility has to be checked at the HTS line-item level, not the entry level or the total duty paid.

How do I find out which of my tariff line items are IEEPA-based?

Pull your CBP entry summaries (Form 7501 or the ACE portal equivalent) and look at the tariff authority code associated with each duty line item, not just the total amount paid. A customs broker can typically isolate IEEPA-based line items from Section 232, 301, 201, and AD/CVD line items relatively quickly, since this data lives at the entry level.

Which 2025 Tariffs Actually Qualify? IEEPA vs. Section 232/301/201/AD-CVD

Q: What did the Supreme Court actually rule in Learning Resources, Inc. v. Trump?

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump (No. 24-1287) that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. This applies specifically to tariffs imposed under IEEPA — it does not affect tariffs imposed under other legal authorities.

1. The Ruling, in Plain English

On February 20, 2026, the Supreme Court decided Learning Resources, Inc. v. Trump (No. 24-1287) in a 6–3 ruling: the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. That's the entire scope of the decision. It's a ruling about one specific legal authority — IEEPA — not a general statement about the legality of every tariff collected in 2025.

In response, U.S. Customs and Border Protection stood up CAPE (Consolidated Administration and Processing of Entries) inside its ACE (Automated Commercial Environment) system, with Phase 1 opening around April 20, 2026. CAPE lets an importer file a single electronic CAPE Declaration — a CSV file — that can cover multiple entries carrying IEEPA tariff line items, rather than filing thousands of individual protests.

If you haven't yet confirmed whether your business even has standing to file a claim, start with our hub on the importer-of-record threshold for every buyer type — this piece assumes you've already cleared that question and is focused specifically on which tariffs qualify once you have.

Source

Supreme Court opinion: supremecourt.gov — Learning Resources, Inc. v. Trump, No. 24-1287. CBP refund mechanism: cbp.gov — IEEPA Duty Refunds.

2. IEEPA vs. Section 232/301/201/AD-CVD — Side by Side

Each of these tariff types is imposed under a different legal authority, for a different stated purpose, by a different statutory process. Only one of them was affected by this ruling.

Tariff Type	Legal Authority	Refundable Under This Ruling?
IEEPA tariffs	International Emergency Economic Powers Act	Yes — may be eligible via CAPE
Section 232 tariffs	Trade Expansion Act, national security	No — not affected by this ruling
Section 301 tariffs	Trade Act, unfair trade practices	No — not affected by this ruling
Section 201 tariffs	Trade Act, safeguard actions	No — not affected by this ruling
AD/CVD duties	Antidumping / countervailing duty orders	No — not affected by this ruling

Every row in the "No" category was imposed under separate legal authority from IEEPA, through separate statutory processes, often years before the 2025 IEEPA tariffs existed. The Supreme Court's ruling doesn't reach any of them — they remain in force and remain non-refundable through this process, regardless of how a given business feels about them.

1 of 5 tariff categories affected by this ruling

6–3 Supreme Court ruling, Feb 20, 2026

HTS line the level eligibility must be checked at

3. Why This Confuses So Many Importers

The confusion is understandable. From an importer's point of view, 2025 was a year of new tariff activity across multiple authorities layered on top of each other — IEEPA tariffs stacked on pre-existing Section 301 tariffs on many China-origin goods, or Section 232 tariffs on commodity categories like steel and aluminum. When a business tallies "how much extra we paid in tariffs in 2025," that total is often a blend of IEEPA and non-IEEPA duty, all showing up on the same monthly duty statement.

Headlines about "the 2025 tariffs being ruled illegal" don't distinguish between authorities either, which reinforces the assumption that the entire 2025 duty increase is now in play. It isn't. The ruling reaches IEEPA tariffs specifically. Everything else on that duty statement — Section 232, 301, 201, AD/CVD — is a separate legal matter, untouched by Learning Resources, Inc. v. Trump, and not eligible for a CAPE refund.

This is also why scrutiny matters when evaluating outside help. An offer that talks about recovering "all your 2025 tariffs" without distinguishing IEEPA from Section 301 either doesn't understand the process or isn't being precise — see verifying a tariff refund offer.

4. One Entry, Two Tariff Types: Why You Have to Check Line by Line

Here's the detail that trips up even careful importers: a single shipment — a single CBP entry — can carry both an IEEPA tariff line item and a Section 301 tariff line item at the same time. These aren't mutually exclusive categories applied at the entry level. They're applied at the HTS (Harmonized Tariff Schedule) line-item level, and a single entry summary can have multiple line items, each governed by a different tariff authority.

That means checking "did I pay extra tariffs on this entry in 2025" isn't enough. The right question is: "which specific line items on this entry were assessed under IEEPA, and which were assessed under Section 232, 301, 201, or AD/CVD?" Only the IEEPA-based line items are potentially refundable. If you total the entry's full duty increase and treat all of it as a refund candidate, you'll overstate your claim — which is exactly the kind of error that can cause a CAPE declaration to stall or get flagged in review.

The core distinction

Check eligibility at the HTS line-item level, not the entry level and not the total duty-paid level. One entry can be partially refundable and partially not, depending on which legal authority each line item falls under.

Not sure which of your entries carry IEEPA line items?

A quick records check can help clarify which portion of your 2025 tariff activity may actually be in play.

Check my eligibility → Free · No obligation · Educational, not legal advice

5. How to Identify Your IEEPA Line Items

Isolating the IEEPA-based portion of your 2025 duty spend takes some entry-level digging, but it's a well-defined task if you know what to look for:

Pull your entry summaries. Your customs broker or freight forwarder can typically produce Form 7501 (or the ACE-portal equivalent) for your 2025 entries.
Look at the tariff authority code on each duty line item — not the entry-level total. Entries filed through ACE carry line-item detail identifying which legal authority (IEEPA, Section 232, 301, 201, or AD/CVD) each duty was assessed under.
Don't rely on your AP or landed-cost summary alone. Summarized accounting data usually nets everything into one "duties and tariffs" line, hiding the IEEPA/non-IEEPA distinction.
Work with a customs broker who can isolate this for you. Brokers who filed your original entries generally hold the line-item detail already and can identify the IEEPA-based portion faster than reconstructing it from scratch.

Once you've isolated the IEEPA-based line items, the next question is timing — whether those entries are unliquidated, recently liquidated, or past the standard filing windows. That's covered in our eligibility hub's deadlines section, and in more filing-mechanics detail in why CAPE claims stall.

6. Next Steps

Getting the IEEPA/non-IEEPA distinction right at the line-item level is the difference between a clean claim and one that stalls in review. Once isolated, the next questions are about standing — see am I eligible: the importer-of-record threshold and not the importer of record? how you can still recover — and timeline, covered in how long does CBP actually take. If you've been offered outside help identifying these line items, run it through the checklist in is this offer a scam before engaging.