Refund status tracker

1. Phase 1 · done

   Ruling

   Supreme Court, Feb 20, 2026: IEEPA does not authorize tariffs. Collection ended Feb 24.

2. Phase 2 · active

   CAPE Phase 1

   Apr 20, 2026: unliquidated entries and entries ≤80 days past liquidation.

3. Phase 3 · active

   CAPE Phase 2

   Jun 29, 2026: entries flagged for reconciliation.

4. Phase 4 · active

   Two-year window

   § 1581(i) suits within two years; deadlines can expire as early as February 2027 if the two years run from payment (Troutman, Aug 13, 2026: 'measured from the date of deposit').

Dated changes

1. Oct 6, 2026 · Effective · US

   CAPE Phase 3 (finally liquidated entries, CIT plaintiffs) set for Oct 6, 2026; CBP's refunds page does not say that it is live (read Oct 8, 2026)

   First set for Aug 20, 2026 (Diaz Trade Law, Aug 21, 2026); delayed while CBP built additional validations (GHY). CAPE Phase 3 (finally liquidated entries; only for importers that sued at the Court of International Trade and whose entries a court ordered reliquidated) was set to deploy on October 6, 2026 (CBP declaration of September 15, as reported). Not yet confirmed on a primary source: CBP's IEEPA refunds page (last modified September 30, 2026; read October 8, 2026) does not say that Phase 3 is live. It does not have the words 'Phase 3', and it lists 'Entries for which liquidation is final' among the types that CBP 'is evaluating' for later CAPE deployments. Plaintiffs should confirm with counsel or their broker before filing.

   C.H. Robinson, Sep 17, 2026, and GHY, updated Oct 5, 2026, reporting CBP's Sep 15 declaration; Diaz Trade Law, Aug 21, 2026 (reported) · reported, not yet verified

2. Sep 11, 2026 · Effective · US

   CBP refund progress: about $134.7B accepted, about $122B certified to Treasury (Sep 11, 2026)

   As of September 11, 2026 (CBP declaration of September 15): 286,044 CAPE declarations (201,293 passing validation); about $134.7 billion accepted into CAPE; 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. Earlier, as of Aug 21, 2026: 272,029 declarations, 26.4M entries accepted, 18.76M (re)liquidated; 22,170 refunds worth $1.7B unsent for missing ACH details. Verified figure for Jul 10: $86.3B sent (CIT order of Jul 15). Reported by trade press (GHY, C.H. Robinson) from CBP's court declaration; the declaration itself is not yet confirmed on a primary source (free search, October 8, 2026). Check CBP's own filings before relying on these figures.

   CBP declaration of Sep 15, 2026 (reported); earlier: CBP's progress report due Aug 25, 2026 (figures as of Aug 21; reported) · GHY summary of CBP's declarations (figures as of Aug 21 and Sep 11, 2026; the later one filed Sep 15, 2026) (updated Oct 5, 2026; reported); C.H. Robinson, Sep 17, 2026 · reported, not yet verified

3. Jul 24, 2026 · Effective · US

   Replacement tariffs: Section 122 surcharge (set to end Jul 24, 2026); Section 301 forced-labor tariffs; Section 338 on Canada

   Proclamation 11012 set the 10% Section 122 surcharge to run from Feb 24, 2026 until 12:01 a.m. on Jul 24, 2026; the statute allows 150 days unless Congress extends the period. The Court of International Trade held it unlawful on May 7, 2026, but ordered refunds only for the importers that sued. The Federal Circuit stayed that order pending appeal on June 11, 2026 (Nos. 2026-1804, -1805; reported by McGuireWoods, June 15, 2026; the court's order not read). CBP's IEEPA refunds page (last modified September 30, 2026; read October 8, 2026) does not name Section 122 duties; Section 301 forced-labor tariffs on 60 economies took effect Jul 24, 2026; Section 338 50% tariffs on designated Canadian goods from Aug 22, 2026 (date reported). None of these are IEEPA duties and none are refundable through CAPE.

   Proclamation 11012 (Sec. 122); CIT Slip Op. 26-47 (May 7, 2026); USTR Sec. 301 final action Jul 23, 2026 (91 FR 47318: from 12:01 a.m. ET Jul 24, 2026) · USTR press release and its Federal Register notice, 91 FR 47318 (Section 301); Diaz Trade Law, Aug 21, 2026 (Section 338 date, reported); CIT Slip Op. 26-47 (Section 122); McGuireWoods, Jun 15, 2026 (the stay, reported) · verified Oct 8, 2026

4. Jul 17, 2026 · Effective · US

   Per-case reliquidation orders for CIT plaintiffs (finally liquidated entries)

   Entered Jul 17, 2026 and made public Jul 21: CBP to reliquidate plaintiffs' entries liquidated more than 80 days ago without regard to IEEPA duties. The order applies only to companies that have filed cases at the Court of International Trade (Thompson Hine, Jul 21, 2026). Reported by a law firm; the order text is not yet confirmed on a primary source (free search, October 8, 2026). If you are a plaintiff, confirm the order in your case with your counsel before acting.

   Freestyle World, Inc. v. United States, No. 26-01088 (lead) · Thompson Hine SmarTrade (reported; order text not located online) · reported, not yet verified

5. Jul 15, 2026 · Effective · US

   CIT status order: Phase 3 reliquidation orders to issue in ~3,700 cases

   Judge Eaton's Jul 15, 2026 order announces per-case orders directing CBP to reliquidate plaintiffs' finally liquidated entries; reports $121.75B accepted and $86.3B sent to Treasury as of Jul 10 (CBP's declaration, ECF 45).

   Euro-Notions Florida v. CBP, No. 25-00595, ECF 46; figures from CBP's Lord declaration, ECF 45 ¶ 5 · CIT order (court filing, copy hosted by Diaz Trade Law) · verified Oct 8, 2026

6. Jul 7, 2026 · Effective · US

   Warehouse entries (types 21/22) rejected from CAPE; withdrawals accepted

   From Jul 7, 2026 CAPE rejects warehouse entry types 21 and 22; withdrawals for consumption (31/32/34/38) are accepted and refunded after liquidation.

   CSMS # 69127837 · CBP CSMS 69127837 · verified Oct 8, 2026

7. Jun 29, 2026 · Effective · US

   CAPE Phase 2: entries flagged for reconciliation

   Deployed Jun 29, 2026 for entry types 01/02/06 flagged for reconciliation where the type-09 entry is not yet on file; still limited to unliquidated or ≤80-day-liquidated entries.

   CSMS # 69066837 · CBP CSMS 69066837 · verified Oct 8, 2026

8. Jun 3, 2026 · Effective · US

   Government appeals the universal-refund orders to the Federal Circuit

   Notices of appeal filed June 3, 2026 in V.O.S. Selections, Euro-Notions and two other cases (reported by Foley, Jun 11, 2026); the Government argues refunds on finally liquidated entries must be importer-specific. Opening brief was due Aug 3; a ruling was 'anticipated later this year' (Troutman, Aug 13, 2026). The two articles we read give no Federal Circuit docket number (read October 8 and 9, 2026). Reported by law firms; not yet confirmed on the court's own docket (free search, October 8, 2026). Confirm with counsel before relying on the outcome of the appeal.

   Appeals of the CIT refund orders of Apr 7 and Apr 17, 2026 (first entered Mar 27, 2026 in Atmus Filtration) · Troutman Pepper Locke (reported); the day of the notices of appeal and the orders appealed: Foley, Jun 11, 2026 (reported) · reported, not yet verified

9. Apr 20, 2026 · Effective · US

   CAPE Phase 1 opens for IEEPA refunds

   Consolidated Administration and Processing of Entries: in the ACE portal, upload a CSV of entry numbers (up to 9,999 per declaration). Refunds by ACH with interest, generally within 60–90 days of acceptance.

   CSMS # 68396594 (Apr 20, 2026); rules in CSMS # 68340863 · CBP CSMS 68396594 (Apr 20, 2026); the 9,999-entry limit and 60–90 days: CSMS 68340863 (Apr 13, 2026) · verified Oct 8, 2026

10. Feb 24, 2026 · Effective · US

    CBP stops collecting IEEPA duties

    Collection ended at 12:00 a.m. ET on Feb 24, 2026. Section 232 and Section 301 duties are not affected.

    CSMS # 67834313; EO 14389 · CBP CSMS 67834313 · verified Oct 8, 2026

11. Feb 20, 2026 · Effective · US

    Supreme Court: IEEPA does not authorize tariffs

    Decided 6–3 on Feb 20, 2026. The majority says nothing about refunds; refund mechanics were left to CBP and the Court of International Trade.

    Learning Resources, Inc. v. Trump, No. 24-1287 (with No. 25-250) · Supreme Court opinion (PDF) · verified Oct 8, 2026

12. Aug 7, 2025 · Effective · US

    Brazil +40% and modified reciprocal rates (9903.02.xx)

    Brazil surcharge effective Aug 6, 2025; modified country rates under new 9903.02 headings from 12:01 a.m. EDT Aug 7, 2025. India +25% followed Aug 27, 2025 (9903.01.84; rescinded Feb 7, 2026).

    EO 14323 (Brazil, 9903.01.77); EO 14326 (9903.02.xx) · EO 14326 text; CBP IEEPA FAQ; the Brazil rate and heading: EO 14323 (90 FR 37739); the India rate, headings and end: EO 14384 of Feb 6, 2026 · verified Oct 8, 2026

13. Apr 5, 2025 · Effective · US

    Reciprocal tariff: 10% baseline (country rates from Apr 9, then paused)

    10% baseline from Apr 5, 2025; country-specific rates from Apr 9, paused the same day to 10% for 90 days except China (EO 14266), extended on Jul 7, 2025 to Aug 1 (EO 14316).

    EO 14257; HTSUS 9903.01.25, 9903.01.43–.76 · EO 14257 text; the pause and its extension: Federal Circuit opinion of Aug 29, 2025 (No. 25-1812) · verified Oct 8, 2026

14. Mar 4, 2025 · Effective · US

    IEEPA tariffs on Canada and Mexico take effect (25%)

    Canadian energy at 10% (9903.01.13); USMCA-qualifying goods excepted. Canada raised to 35% on Aug 1, 2025 (EO 14325).

    EO 14193 / EO 14194; HTSUS 9903.01.01–.15 · CBP IEEPA FAQ; the 35% rate: EO 14325 (90 FR 37957) · verified Oct 8, 2026

15. Feb 4, 2025 · Effective · US

    IEEPA tariff on China takes effect (10%, raised to 20% Mar 4, 2025)

    The first IEEPA tariff. Raised to 20% on Mar 4, 2025 (EO 14228) and cut back to 10% on Nov 10, 2025 (EO 14357).

    EO 14195; EO 14228 (90 FR 11463) and CBP notice 90 FR 11426 (20% from Mar 4, 2025); EO 14357 (90 FR 50725; 10% from Nov 10, 2025); HTSUS 9903.01.20 / 9903.01.24 · CBP IEEPA FAQ (start date); rate changes in the Federal Register (see the cited orders) · verified Oct 8, 2026