IEEPA tariff refund status: what CBP has paid, what is open, and what comes next

Status as of October 8, 2026. Every row below is also in the status tracker with its source; this page is the narrative.

What is live

• CAPE Phase 1 (April 20, 2026): unliquidated entries and entries liquidated 80 days ago or less. Open; CBP's page states no closing date (read October 8, 2026).
• CAPE Phase 2 (June 29, 2026): entries flagged for reconciliation. Open.
• Carrier-cleared parcels: under CBP's rule the broker that filed the entry may file for it. On September 16, 2026 UPS's and FedEx's pages described refund programs for the parcels they cleared (not re-read since).
• Court orders for plaintiffs: on July 17, 2026 (made public July 21) the Court of International Trade ordered CBP to reliquidate the plaintiffs' finally liquidated entries in about 3,700 cases (reported from the court's July 15 order and a law-firm summary).

What CBP has paid

By July 10, 2026 (stated in the court's July 15 order): $121.75 billion accepted in CAPE and $86.3 billion certified and sent to the Treasury; 9,837 refunds held for missing ACH details. By August 21, 2026 (CBP declaration of August 25, reported): $132.5 billion accepted, $106.6 billion sent; 272,029 declarations covering 26.4 million entries; 22,170 refunds worth $1.7 billion unsent for missing ACH. By September 11, 2026 (CBP declaration of September 15, reported): 286,044 CAPE declarations (201,293 passing validation); about $134.7 billion accepted; about $122 billion (including interest) certified to the Treasury; 20,184 refunds (about $1.3 billion) on hold because the importer has not given bank (ACH) details. The starting point was ≈$166 billion from 330,000+ importers (CBP, March 6, 2026).

What is pending

• CAPE Phase 3 for finally liquidated entries: postponed from August 20; set to deploy on October 6, 2026 (CBP declaration of September 15, as reported), only for importers that sued at the Court of International Trade and whose entries a court ordered reliquidated. CBP's IEEPA refunds page does not say that it is live (read October 8, 2026).
• The Federal Circuit appeal of the CIT's universal-refund orders (filed in June 2026, reported). If the Government wins, finally liquidated entries stay per-plaintiff; if it loses, CBP may have to refund them universally. A ruling was 'anticipated later this year' (Troutman, August 13, 2026).
• Class certification in Freestyle World v. United States (oral argument was set for August 19, 2026, per Troutman, August 13, 2026; no text that we read on October 8 and 9, 2026 says what followed).
• CBP functionality for entries with open protests, which the July 15 order says is under discussion.

The clocks running now

• 80 days after liquidation — the CAPE limit per entry.
• 180 days after liquidation — the protest right (19 U.S.C. § 1514).
• Two years — § 1581(i) suits (28 U.S.C. § 2636(i)); deadlines can expire as early as February 2027 if the two years run from payment. Troutman (August 13, 2026) says that the two years are "measured from the date of deposit"; ask counsel before relying on any date. Details in the deadlines guide.

Not part of the refund process

Section 122 (set by Proclamation 11012 to end on July 24, 2026; held unlawful by the Court of International Trade on May 7, 2026, with refunds ordered only for the importers that sued; the Federal Circuit stayed that order pending appeal on June 11, 2026 (reported by McGuireWoods, June 15, 2026; the court's order not read); CBP's IEEPA refunds page, read October 8, 2026, does not name Section 122 duties: ask counsel about your deadlines), Section 301 forced-labor tariffs (from July 24, 2026), Section 338 tariffs on Canadian goods (from August 22, 2026, reported), and all Section 232 duties. The consumer rebate bills were referred to committee.

General information from public sources, not legal advice. Checked October 8, 2026; the carriers' pages were last read September 16, 2026. Each fact shows the date we last checked it, and we re-check before every update.