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.

Money tracker

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.

$166B Paid in IEEPA tariffs

CBP's estimate of what it collected from February 2025 to February 2026.

$134.7B Accepted into CAPE

Refund requests CBP has taken in for processing, covering about 27.2 million entries.

$122B Sent for payment

Approved refunds sent to the Treasury to pay out, with interest.

How far along it is

Share of the $166 billion in IEEPA tariffs.

Accepted into CAPEAbout 81%
Sent for paymentAbout 73%
$1.3B

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.

$23.7B
$100B
$106.6B
$122B

Rounded from CBP's progress reports to the court.

Refund phases

Which phase covers what

CBP is opening refunds in stages. Which one applies depends on where your entry stands.

  1. Open

    Phase 1

    Since April 20, 2026

    Entries that haven't liquidated yet, or liquidated within the last 80 days.

  2. Open

    Phase 2

    Since June 29, 2026

    Entries flagged for reconciliation that don't have a reconciliation entry filed yet.

  3. Opens Oct 6

    Phase 3

    Since October 6, 2026

    Finally liquidated entries covered by a court order, for importers with their own case.

  4. 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.

It's finally liquidated

CBP finalized the duty bill and the 180-day window to dispute it has passed. In other words, the entry is closed out.

You have a pending case

Your company filed its own IEEPA refund case at the Court of International Trade, and it's still open.

A court order covers it

The court told CBP to reliquidate the entry, meaning recalculate the duty bill without the IEEPA tariffs.

Importer number in by July 30, 2026You can file starting October 6.
Importer number sent after July 30You're not shut out. CBP says it'll send more instructions.

Not sure if an entry is finally liquidated? Our entry status guide explains each stage →

Full timeline

Every date, start to now

Filter by what you care about. The orange marker moves on its own as dates pass.

DoneUp nextComing

2025

  1. Early Feb
    Background

    First IEEPA tariffs start

    Tariffs on goods from China take effect. This is where the refund window starts for those entries.

  2. Mar 4
    Background

    Canada and Mexico tariffs start

    IEEPA tariffs extend to many goods from Canada and Mexico.

  3. April
    Background

    Country-by-country tariffs start

    New IEEPA tariff rates hit imports from most countries.

2026

  1. Feb 20
    Court 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.

  2. Feb 24
    Refund process

    CBP stops collecting IEEPA tariffs

    No new IEEPA duties after this date.

  3. Mar 4
    Court 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.

  4. Mar 27
    Court ruling

    The order widens to older entries

    The court extended it to entries that had already liquidated, including fully closed-out ones.

  5. Apr 20
    Refund 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.

  6. May 29
    Refund process

    CBP changes course on closed-out entries

    CBP said it can't refund finally liquidated entries without a court order.

  7. Jun 2
    Court ruling

    The government appeals

    It took the trade court's broad refund orders to the Federal Circuit, a higher court.

  8. Jun 29
    Refund process

    Phase 2 opens

    CAPE starts taking entries flagged for reconciliation that don't have a reconciliation entry filed yet.

  9. Jul 7
    Refund 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.

  10. Jul 17
    Court 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.

  11. Jul 30
    Deadline

    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.

  12. Aug 10
    Court 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.

  13. Aug 25
    Refund 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.

  14. Sep 15
    Refund 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.

  15. Oct 6
    Refund process

    Phase 3 opens Next up

    Plaintiffs whose importer number reached CBP by July 30 can start filing for finally liquidated entries covered by a court order.

  16. After Oct 6
    Refund 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.

  17. Late 2026
    Court 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

  1. Early 2027
    Deadline

    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.

Still open

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 yet

Phase 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 CBP

Later importer-number filers

Instructions for plaintiffs whose importer number reached CBP after July 30.

Waiting on CBP

Group cases at the trade court

Some cases ask the court to cover whole groups of importers, not only the ones who sued.

No ruling yet

Not 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.