CBP's latest declaration reports 252,496 CAPE declarations covering about 25.1 million import entries. Of $128.68 billion in potential plus certified refunds accepted for CAPE processing, roughly $100 billion had been completed, certified, and sent to Treasury for disbursement as of July 31. Treasury updates indicated refunds were being regularly disbursed, but the declaration did not say the full $100 billion had reached importers. Individual timing still varies, and finally liquidated entries remain outside CAPE.
Primary source: Brandon Lord declaration, filed Aug. 4, 2026 →Appeal update: government opening brief reported Aug. 11, 2026 →Last updated: August 11, 2026
CBP reported 19,726 refunds totaling about $1.6 billion had not been transmitted to Treasury because ACH information was missing as of July 31. 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 →CBP reported 19,726 refunds totaling about $1.6 billion had not been transmitted to Treasury because ACH information was missing as of July 31. Confirm ACE Portal access, importer sub-account access, Trade Account Owner coverage, and ACH refund enrollment before your entry moves through CAPE.
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.
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.
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.
The CIT issued its first Phase 3 procedure order for litigating plaintiffs with entries liquidated more than 80 days, but broader access and open-protest functionality remain unresolved. Although Appeal No. 2026-1898 was dismissed, the government filed an August 10 opening brief challenging universal relief for non-party importers. Coordinate case-specific eligibility and preservation with counsel.
Supreme Court rules 6-3 in Learning Resources v. Trump that IEEPA does not authorize presidential tariffs. $166B in duties deemed unlawful.
Customs and Border Protection issues guidance: IEEPA duties will no longer be applied to new import entries effective February 24.
New entries processed without IEEPA tariffs. However, ACE system continues liquidating previously filed entries with IEEPA tariffs applied.
Federal Circuit denies government request to delay proceedings. Mandates issued "forthwith," sending case back to Court of International Trade.
Judge Eaton orders CBP to refund ALL IEEPA tariffs — 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.
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.
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.
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).
MAJOR: CIT orders reliquidation of "finally liquidated entries" beyond the 180-day protest window. This removes a huge administrative hurdle — previously these entries were thought to be ineligible. CBP will handle in a later CAPE phase.
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%.
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.
The government filed a notice of appeal from the April 7 injunction. The appeal is docketed as Federal Circuit No. 2026-1898.
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.
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.
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.
After a closed conference, the court ordered another CAPE status report by July 1 and set a July 9 closed settlement conference.
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.
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.
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.
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.
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.
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.
ECF 52 directed CBP to reliquidate litigating plaintiffs' IEEPA-duty entries liquidated more than 80 days after plaintiffs' counsel supplies importer IDs and CBP accepts the CAPE declarations. This is a case-linked procedure, not a public opening of Phase 3 to every importer. Euro-Notions was dismissed, and the court directed Zonos to refile its postal-stream request in Freestyle World.
The Federal Circuit granted the motion to deconsolidate and dismiss Appeal No. 2026-1898. The mandate issued the same day, with each side bearing its own costs. That disposition did not eliminate the government's broader challenge to universal refund relief.
In the Freestyle World declaration, CBP Executive Director Brandon Lord reported 252,496 CAPE declarations covering about 25.1 million import entries and $128.68B in potential plus certified refunds accepted for processing. Roughly $100B had been completed, certified by CBP, and sent to Treasury for disbursement as of July 31. Treasury updates indicated refunds were being regularly disbursed, but the declaration did not say the full $100B had reached importers.
ECF 25 states that the July 17 reliquidation procedure order has been entered in more than 3,700 cases and directs the government to file another CAPE progress report by August 25. In ECF 26, Judge Eaton separately asked whether CBP has any protocol that could delete entry information tied to IEEPA estimated deposits made between February 1, 2025 and February 25, 2026.
According to the Associated Press, the government filed its opening Federal Circuit brief challenging refund relief for non-party importers. It argues that a universal injunction cannot be squared with Trump v. CASA and says importers with finally liquidated entries may instead file individual CIT actions within the statute of limitations.
The government must file a short CAPE progress report by 5 PM ET on August 25. The court will hold its next closed settlement conference on August 26 at 2 PM ET, in person and by Webex.
CBP has accepted about $128.68 billion in potential or certified refunds for CAPE processing, and roughly $100 billion had been completed, certified, and sent to Treasury for disbursement as of July 31. Your potential refund depends on import volume, product mix, entry status, validation results, and ACH readiness.
These are rough estimates based on average IEEPA duty rates. For a personalized analysis, use our calculator.
Appeal No. 2026-1898 was dismissed on July 28, but that did not end the broader appellate fight. The government filed an opening brief on August 10 challenging universal relief for non-party importers under Trump v. CASA. The dispute is concentrated in finally liquidated entries; CAPE processing for other eligible categories continues.
The CIT says its July 17 reliquidation procedure order has been entered in more than 3,700 cases. The order requires counsel-submitted importer IDs and accepted CAPE declarations; broader rollout timing, validation rules, open-protest functionality, and CBP data-retention safeguards are not yet fully public.
CBP reported 19,726 refunds totaling about $1.6B had not been transmitted to Treasury because required ACH information was missing as of July 31. Without valid ACE/ACH refund enrollment, a refund can be certified but not actually reach the importer.
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.
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.
Before you negotiate, sell, or wait — understand the probability-weighted value of your IEEPA tariff refund claim.
Calculate Your Refund Value →