IEEPA refund hub / Key dates
Key dates and refund tracker
Every phase, court ruling, and cutoff in one place, plus how much money has actually gone back to importers. We update this page as CBP and the courts move.
Last updated October 2026. Refund figures as of September 11, 2026.
Where the refund money stands
These numbers come from CBP's reports to the Court of International Trade. They're rounded, and they move every few weeks.
CBP's estimate of what it collected from February 2025 to February 2026.
Refund requests CBP has taken in for processing, covering about 27.2 million entries.
Approved refunds sent to the Treasury to pay out, with interest.
How far along it is
Share of the $166 billion in IEEPA tariffs.
in approved refunds was on hold as of September 11 because importers hadn't added refund bank details in ACE. How to set that up →
Money sent for payment over time
Running total, in billions of dollars.
Rounded from CBP's progress reports to the court.
Which phase covers what
CBP is opening refunds in stages. Which one applies depends on where your entry stands.
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Open
Phase 1
Since April 20, 2026
Entries that haven't liquidated yet, or liquidated within the last 80 days.
80 days ago was Liquidated since then? Phase 1 may still fit. -
Open
Phase 2
Since June 29, 2026
Entries flagged for reconciliation that don't have a reconciliation entry filed yet.
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Opens Oct 6
Phase 3
Since October 6, 2026
Finally liquidated entries covered by a court order, for importers with their own case.
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Waiting on appeal
Closed out, no case
No date yet
No CAPE path right now. Filing your own case may still be an option, so talk with a customs attorney. The appeal could also change this.
Phase 3 in plain English
All three have to be true for an entry to qualify.
CBP finalized the duty bill and the 180-day window to dispute it has passed. In other words, the entry is closed out.
Your company filed its own IEEPA refund case at the Court of International Trade, and it's still open.
The court told CBP to reliquidate the entry, meaning recalculate the duty bill without the IEEPA tariffs.
Not sure if an entry is finally liquidated? Our entry status guide explains each stage →
Every date, start to now
Filter by what you care about. The orange marker moves on its own as dates pass.
DoneUp nextComing
2025
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Early FebBackground
First IEEPA tariffs start
Tariffs on goods from China take effect. This is where the refund window starts for those entries.
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Mar 4Background
Canada and Mexico tariffs start
IEEPA tariffs extend to many goods from Canada and Mexico.
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AprilBackground
Country-by-country tariffs start
New IEEPA tariff rates hit imports from most countries.
2026
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Feb 20Court ruling
Supreme Court rules the tariffs unlawful
In a 6-3 decision, the Court said IEEPA doesn't let the President set tariffs. That's what opened the door to refunds.
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Feb 24Refund process
CBP stops collecting IEEPA tariffs
No new IEEPA duties after this date.
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Mar 4Court ruling
Trade court orders refunds on open entries
The Court of International Trade told CBP to refund IEEPA duties on entries that hadn't liquidated yet, meaning CBP hadn't finalized the duty bill.
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Mar 27Court ruling
The order widens to older entries
The court extended it to entries that had already liquidated, including fully closed-out ones.
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Apr 20Refund process
Phase 1 opens
CBP's refund tool, CAPE, goes live in the ACE Portal. Importers and brokers can start filing for open and recently liquidated entries.
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May 29Refund process
CBP changes course on closed-out entries
CBP said it can't refund finally liquidated entries without a court order.
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Jun 2Court ruling
The government appeals
It took the trade court's broad refund orders to the Federal Circuit, a higher court.
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Jun 29Refund process
Phase 2 opens
CAPE starts taking entries flagged for reconciliation that don't have a reconciliation entry filed yet.
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Jul 7Refund process
Change for bonded warehouse entries
CAPE stopped accepting warehouse entries. Refunds are claimed on the withdrawals instead, since that's when the duties were paid.
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Jul 17Court ruling
Court orders refunds on closed-out entries, for plaintiffs
The trade court told CBP to reliquidate finally liquidated entries for importers with their own pending case. Phase 3 is built on this order.
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Jul 30Deadline
Importer number cutoff for Phase 3's first day
Plaintiffs who gave CBP a valid importer of record number by this date can file on October 6.
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Aug 10Court ruling
The government asks to cancel the broad refund orders
If it wins, importers with closed-out entries who never sued could lose their path to a refund.
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Aug 25Refund process
Phase 3 gets pushed back
It was set for August 20. CBP delayed it to add checks that make sure only IEEPA duties get refunded.
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Sep 15Refund process
CBP confirms the Phase 3 date
In a court filing, CBP set October 6 for Phase 3 and reported $122 billion sent for payment as of September 11.
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Oct 6Refund process
Phase 3 opens
Plaintiffs whose importer number reached CBP by July 30 can start filing for finally liquidated entries covered by a court order.
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After Oct 6Refund process
Instructions for later importer-number filers
Plaintiffs whose number reached CBP after July 30 aren't shut out. CBP says it'll send them instructions.
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Late 2026Court ruling
Appeals court decision expected
The Federal Circuit decides whether importers who never sued can get refunds on closed-out entries. No date is set.
2027
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Early 2027Deadline
The window to go to court starts closing
There's generally a two-year limit to bring a case at the Court of International Trade, and for the earliest IEEPA entries it runs out in early 2027. If your entries are closed out and you haven't filed, talk with a customs attorney about timing.
What we're watching
These could change who qualifies or when money moves. Sign up for updates and we'll email you when something changes.
The government's appeal
The Federal Circuit will decide whether importers who never sued can get refunds on closed-out entries.
No decision yetPhase 3 filing instructions
CBP hasn't posted step-by-step instructions for filing in Phase 3 yet. We'll add them here once it does.
Watching CBPLater importer-number filers
Instructions for plaintiffs whose importer number reached CBP after July 30.
Waiting on CBPGroup cases at the trade court
Some cases ask the court to cover whole groups of importers, not only the ones who sued.
No ruling yetNot sure which date applies to you?
Send us what you have. We'll help you gather the right information, get organized, and figure out the next step.