Refund Status โ€” Updated

IEEPA Tariff Refund: $86.3B Sent; Phase 3 Procedure Orders Planned

As of CBP's July 13 filing, CAPE has accepted 24.4 million entries for IEEPA-duty removal, with about $86.3 billion completed, certified, and sent to Treasury. The CIT announced Freestyle World as the next CAPE vehicle and plans future procedure orders for certain finally liquidated entries across roughly 3,700 assigned cases. The next report is due August 4.

Last updated: July 19, 2026 at 4:55 AM ET

๐Ÿšจ

Paper Checks Discontinued โ€” Electronic Enrollment Required

CBP reported 9,837 consolidated refunds blocked for missing ACH information as of July 10. Paper checks have been discontinued. ACH/electronic is the core payment path, and CBP's official refund page points importers to ACE account support and automation for common account-management problems. If your ACE/ACH setup is stale, your refund can be delayed even after CAPE processing accepts the entry.

Set Up Your ACE & ACH Now โ†’

๐Ÿ“Š By the Numbers (CBP Declaration, July 13)

229,609
CAPE Declarations Submitted
161,792
Passed File Validations
24.4M
Entries Accepted for IEEPA-Duty Removal
16.74M
Liquidated/Reliquidated Without IEEPA Duties
$121.75B
Potential/Certified Refunds Accepted for CAPE
$86.3B
Certified and Sent to Treasury
9,837
Refunds Blocked for Missing ACH

๐Ÿ“‹ What You Should Do Right Now

1

Enroll for Electronic Refunds ImmediatelyUrgent

CBP reported 9,837 consolidated refunds blocked for missing ACH information. Confirm ACE Portal access, importer sub-account access, Trade Account Owner coverage, and ACH refund enrollment before your entry moves through CAPE.

2

Check Reconciliation and Warehouse Entry RulesUrgent

CBP reported 1.97M reconciliation-flagged entries filed and processing as of July 10. Effective July 7, warehouse entry types 21/22 are no longer CAPE-eligible, while withdrawal types 31/32/34/38 remain eligible; some earlier warehouse filings must be refiled with withdrawal entries.

3

Gather Entry Documentation

Collect all entry summaries, commercial invoices, and proof of IEEPA duty payments. CBP says entry numbers beginning with zero should be formatted with a leading apostrophe in CAPE CSV files so Excel does not strip the zero.

4

Coordinate with Your Customs Broker

Your broker will be the primary interface with CBP's new automated system. Confirm they're tracking the March 12 plan filing and can process your refund entries.

5

Track Phase 3, Protests, and the Appeal

The CIT plans future Phase 3 procedure orders for certain finally liquidated entries across roughly 3,700 assigned cases, CBP is evaluating open-protest functionality, and Federal Circuit No. 2026-1898 remains active. Coordinate edge-category preservation with counsel.

๐Ÿ“… Refund Timeline

โš–๏ธFeb 20, 2026

SCOTUS Strikes Down IEEPA Tariffs

Supreme Court rules 6-3 in Learning Resources v. Trump that IEEPA does not authorize presidential tariffs. $166B in duties deemed unlawful.

๐Ÿ›ƒFeb 22, 2026

CBP Stops Assessing IEEPA Duties

Customs and Border Protection issues guidance: IEEPA duties will no longer be applied to new import entries effective February 24.

๐Ÿ“‹Feb 24, 2026

IEEPA Duties No Longer Applied

New entries processed without IEEPA tariffs. However, ACE system continues liquidating previously filed entries with IEEPA tariffs applied.

๐Ÿ›๏ธMar 2, 2026

Federal Circuit Denies DOJ Stay

Federal Circuit denies government request to delay proceedings. Mandates issued "forthwith," sending case back to Court of International Trade.

๐Ÿ“œMar 4, 2026

CIT Orders Universal Refund

Judge Eaton orders CBP to refund ALL IEEPA tariffs โ€” both liquidated and unliquidated entries. CBP ordered to stop calculating IEEPA tariffs on customs paperwork. Judge Eaton designated sole judge for all IEEPA refund cases.

๐Ÿ”ดMar 6, 2026

Conference: CBP Says "Cannot Comply Immediately"

CBP Executive Director Brandon Lord files declaration: 330,000 importers, 53 million entries, 1.6 billion entry lines, 4.4 million man-hours needed for manual processing. $166B official total. Only 21,000 of 330,000 importers (6.4%) have ACH accounts. CBP proposes 45-day automated ACE refund system build. Judge Eaton suspends immediate refund order pending CBP plan.

๐Ÿ“…Mar 12, 2026

CBP Files Detailed CAPE Refund Plan

CBP submits its concrete CAPE system plan via the ACE system, detailing the technical approach, 4-component architecture, prioritization of entry types, and specific timeline milestones.

๐ŸŒMar 20, 2026

CIT Expands Scope to ALL IEEPA Tariffs

Judge Eaton amends the refund order to cover ALL IEEPA tariffs, including Brazil and India imports. De minimis entries excluded (separate litigation: Axle of Dearborn Inc. v. Dept of Commerce).

๐Ÿ”“Mar 27, 2026

Finally Liquidated Entries Now Eligible

MAJOR: CIT orders reliquidation of "finally liquidated entries" beyond the 180-day protest window. This removes a huge administrative hurdle โ€” previously these entries were thought to be ineligible. CBP will handle in a later CAPE phase.

โœ…Apr 1, 2026

CIT Confirms April 20 Launch On Track

Judge Eaton confirms government "continues to make satisfactory progress" and is "on track to meet the April 20, 2026 deadline" for CAPE Phase 1. CAPE build status: Claim Portal ~85%, Mass Processing ~60%, Review & Reliquidation ~80%, Refund ~75%.

๐Ÿ“‹Apr 20, 2026

CAPE Phase 1 Launches in ACE

CBP opened CAPE declarations in ACE for eligible IEEPA-duty refunds. Phase 1 accepted qualifying entry summaries while deferring more complex categories such as reconciliation-flagged entries.

๐Ÿ›๏ธJune 2-3, 2026

Government Appeals to the Federal Circuit

The government filed a notice of appeal from the April 7 injunction. The appeal is docketed as Federal Circuit No. 2026-1898.

๐Ÿ“ŠJune 10, 2026

CBP Files Updated CAPE Volumes

Brandon Lord reported 181,155 CAPE declarations submitted, 125,576 passing file validations, 16.74M entries accepted for IEEPA-duty removal, $94.94B accepted for CAPE processing, and $23.68B completed, certified, and sent to Treasury.

๐ŸงพJune 12, 2026

Court Sets June 29 Reconciliation-Flag Phase

The court reported CBP is on track to launch the next CAPE phase on June 29 for entries flagged for reconciliation where no Type 09 reconciliation entry has been filed and the entry remains unliquidated or within 80 days of liquidation.

โš–๏ธJune 17, 2026

Tariffed-Payor Amicus Motion Filed

Putative tariffed-payor class counsel moved to participate as amici and asked the court to adjust CAPE refund procedures to preserve and coordinate claims by parties that allegedly bore IEEPA tariff costs but are not importers of record.

๐Ÿ–ฅ๏ธJune 25, 2026

Closed CIT Conference

After a closed conference, the court ordered another CAPE status report by July 1 and set a July 9 closed settlement conference.

๐Ÿ”„June 29, 2026

Reconciliation-Flagged Entry Phase Deploys

CBP deployed CAPE functionality for certain reconciliation-flagged entry types 01, 02, and 06 where no reconciliation entry has been filed. By 5 PM ET June 30, about 1.6M reconciliation-flagged entries had been filed in CAPE and queued for processing.

๐Ÿ“…July 1, 2026

CBP Files ECF 39 Progress Report

Brandon Lord reported 213,939 CAPE declarations submitted, 149,840 passing file validations, 18.1M entries accepted for IEEPA-duty removal, $104.29B accepted for CAPE processing, and $71.06B completed, certified, and sent to Treasury.

๐ŸงพJuly 2, 2026

CIT Confirms Phase 2 and Sets Next CAPE Report

ECF 40 confirmed CAPE Phase 2 launched for reconciliation-flagged entries with no Type 09 reconciliation entry, noted CBP is developing Phase 3 for finally liquidated entries where reliquidation has been ordered in litigation, and ordered the next CAPE progress report by July 13.

๐Ÿ“ŠJuly 13, 2026

CBP Reports $86.3B Sent to Treasury

ECF 45 reported 229,609 CAPE declarations, 24.4M entries accepted for IEEPA-duty removal, $121.75B in potential plus certified refunds accepted for processing, and $86.3B completed, certified, and sent to Treasury.

๐Ÿ›๏ธJuly 15-16, 2026

CIT Announces Freestyle as Next CAPE Vehicle

After the July 14 conference, ECF 46 said the court will lift the stay in Freestyle World and plans future procedure orders for certain finally liquidated entries across roughly 3,700 assigned IEEPA cases. Open-protest functionality remains under discussion. Euro-Notions voluntarily dismissed on July 16.

โš–๏ธJuly 17, 2026

Leave to File Tariffed-Payor Amicus Brief Denied

ECF 49 denied leave to file the June 17 tariffed-payor amici brief; it was not a merits ruling on those claims. A separate postal-stream issue raised by Zonos remains distinct because those shipments were paid through aggregated international-mail worksheets rather than normal entry summaries.

๐Ÿ“…August 4-5, 2026Next Deadline

Next CAPE Report and Closed Conference

The next short CAPE progress report is due August 4 at 5:00 PM ET, followed by a closed status conference on August 5 at 2:00 PM ET.

๐Ÿ’ฐ Estimated Refund Ranges

CBP has accepted about $121.75 billion in potential or certified refunds for CAPE processing, and about $86.3 billion has been completed, certified, and sent to Treasury. Your potential refund depends on import volume, product mix, entry status, validation results, and ACH readiness.

$50Kโ€“$250K
Small Importer
$1Mโ€“$5M annual imports
$250Kโ€“$2.5M
Mid-Size Importer
$5Mโ€“$50M annual imports
$2.5M+
Large Importer
$50M+ annual imports

These are rough estimates based on average IEEPA duty rates. For a personalized analysis, use our calculator.

โš ๏ธ What Could Delay Your Refund

Federal Circuit Appeal

Medium Likelihood

The government has appealed the April 7 injunction to the Federal Circuit, docketed as No. 2026-1898. CAPE processing is continuing, but appellate activity can still affect timing, scope, or finality for contested categories.

Phase 3 and Protest Rollout

Medium Likelihood

The CIT plans future Phase 3 procedure orders for certain finally liquidated entries across roughly 3,700 assigned IEEPA cases. CBP is still developing Phase 3 and evaluating open-protest functionality; timing and validation rules are not yet fully public.

ACH Payment Blockers

Medium Likelihood

CBP reported 9,837 consolidated refunds blocked for missing ACH information as of July 10. Without valid ACE/ACH refund enrollment, a refund can be certified but not actually reach the importer.

Section 122 Replacement Tariffs

Medium Likelihood

Treasury Secretary Bessent has signaled a new 15% global tariff under Section 122 to replace IEEPA duties. This does NOT affect refund rights for past IEEPA duties, but creates new costs for importers going forward.

Postal-Stream Claims

Medium Likelihood

The court denied leave to file the broader tariffed-payor amici brief on July 17 without reaching the merits. Zonos separately documented a postal-payment structure with aggregated worksheets and Pay.gov remittances rather than standard entry summaries, leaving that operational refund path unresolved.

๐Ÿ“š Related Resources

Know What Your Claim Is Worth

Before you negotiate, sell, or wait โ€” understand the probability-weighted value of your IEEPA tariff refund claim.

Calculate Your Refund Value โ†’