The IEEPA Refund Timeline: Where Things Stand and What Importers Should Do Now

On February 20, 2026, the U.S. Supreme Court issued its decision in Learning Resources, Inc. v. Trump, holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. The ruling effectively struck down tariffs on imports from China (up to 145%), Canada (25%), and Mexico (25%) — tariffs that had generated approximately $166 billion in duties paid by more than 300,000 U.S. importers across over 53 million entries.

The decision was historic, but it did not automatically trigger refunds. What followed has been a rapid and evolving sequence of court orders, government responses, and system-building efforts by U.S. Customs and Border Protection (CBP). This article provides a detailed timeline of events, an explanation of the refund system being built, and practical guidance for importers who want to position themselves for the fastest possible recovery.

The Timeline: From Supreme Court to CAPE

February 20, 2026 — The Supreme Court Rules

In Learning Resources, Inc. v. Trump, the Supreme Court held that "IEEPA does not authorize the President to impose tariffs." The decision was clear and unambiguous. However, the Court did not address the mechanics of refunds — that question was left to the lower courts and to CBP.

February 27, 2026 — First Refund Case Filed

Atmus Filtration, Inc. filed a case at the U.S. Court of International Trade (CIT), case number 26-01259, seeking refunds of IEEPA duties. This became the lead case through which the refund process would be shaped.

March 4, 2026 — CIT Orders Immediate Refunds

Judge Eaton of the CIT entered a sweeping order directing CBP to begin the process of refunding all tariffs collected under IEEPA to all importers of record — regardless of whether they had individually filed suit. This was a significant development: it meant that every affected importer, not just the plaintiffs, would be entitled to refunds.

March 5, 2026 — CIT Amends the Order

The CIT issued an amended order narrowing the scope to IEEPA duties "imposed by the Executive Orders considered by the Supreme Court in Learning Resources." This clarification was important for defining exactly which tariff actions were covered.

March 6, 2026 — CBP Responds: Cannot Immediately Comply

CBP filed a declaration from Brandon Lord, a senior CBP official, stating that the agency could not immediately remove and refund IEEPA duties through the traditional entry-by-entry liquidation and reliquidation process. CBP cited an "unprecedented volume of refunds" and insufficient technology, processes, and resources to comply on the court's timeline.

However, CBP did not simply refuse. Instead, Lord outlined a plan: CBP would build a new, multi-step automated refund system within the Automated Commercial Environment (ACE). Lord estimated the system could be operational within approximately 45 days — targeting late April 2026.

Following a closed-door status conference on March 6, Judge Eaton suspended the immediate refund requirement and directed CBP to provide a progress report by March 12.

March 12, 2026 — CBP Files First Progress Report

CBP filed its first detailed progress report, and the picture became significantly clearer. The new system is called CAPE — the Consolidated Administration and Processing of Entries. As of March 11, 2026, CBP reported the following completion status:

CBP indicated that CAPE will be developed in phases. The first phase will handle the majority of formal and informal entries on which IEEPA duties were paid. However, certain complex entry types will require later phases — including entries subject to antidumping or countervailing duties, entries with "Suspended," "Extended," or "Under Review" liquidation status, warehouse withdrawals, and entries designated on drawback claims.

How the CAPE System Will Work

Based on CBP's declarations to the CIT, the CAPE system will operate through four integrated components:

1. Claim Portal

Importers and customs brokers will access a web-based portal within ACE to submit IEEPA refund requests. These requests are called "CAPE Declarations." Filers will upload a Comma-Separated Values (CSV) file containing a list of entry summaries for which they are requesting refunds. ACE will validate both the CSV file format and the individual entries contained within it.

2. Mass Processing

Once a CAPE Declaration is accepted, the system will check the Harmonized Tariff Schedule (HTS) number of each entry and separate IEEPA HTS numbers from non-IEEPA numbers. It will then recalculate the importer's duties as if the IEEPA tariffs had never been applied. This automated step is designed to handle the bulk of the computational work at scale.

3. Review and Liquidation/Reliquidation

After mass processing, CBP will initiate the formal liquidation or reliquidation process for each entry. The system will automatically set liquidation dates based on when the CAPE Declaration was accepted. CBP will use the intervening period to conduct any necessary manual reviews. This component also calculates interest owed to importers.

4. Electronic Refund

Refunds will be consolidated and processed electronically to designated ACH accounts. Importers must be enrolled in CBP's ACH Refund program to receive payments. Notably, CBP's declaration states that importers will be able to designate a third party to receive refunds on their behalf by completing a CBP Form 4811 — a detail that could be significant for companies that have sold or assigned their refund claims.

What This Means for Importers

The progress is real, but importers should not expect automatic refunds. The system is being built, not yet operational. Here is what companies should be doing right now:

Verify Your ACE Account

Ensure your company's ACE account is active and properly configured. If you do not have an ACE account, work with your customs broker to establish one. This is the platform through which CAPE Declarations will be submitted.

Enroll in ACH Electronic Refunds

As of February 6, 2026, CBP moved to an all-electronic refund system — no more paper checks. If your company is not enrolled in CBP's ACH Refund program, you will not be able to receive refunds when they are processed. This is a critical step that many importers have not yet completed.

Organize Your Entry Data

Start gathering and organizing your entry summaries (CBP Form 7501), commercial invoices, and bills of lading for all entries on which IEEPA duties were paid. The CAPE system will require CSV uploads of entry data, so having this information organized and ready will position you to submit claims quickly once the portal opens.

Identify Which Entries Were IEEPA-Specific

Not all tariffs on Chinese, Canadian, or Mexican goods were IEEPA tariffs. Section 301 duties, antidumping duties, and countervailing duties remain in effect. You need to identify specifically which of your entries were assessed IEEPA tariffs — your customs broker or trade compliance team can help with this analysis.

Monitor the Phased Rollout

CBP has indicated that CAPE will launch in phases. Phase 1 will cover the majority of standard entries, but complex entries may require later phases. Stay informed about which entry types are eligible in each phase so you can submit claims at the earliest opportunity.

Interest Is Accruing — Every Day Matters

One detail that importers should not overlook: interest on IEEPA refunds is accruing at 6% annually. On $166 billion in total duties, that represents approximately $650 million per month in interest across all affected importers. The longer the refund process takes, the larger the total payout — but the sooner you are positioned to file, the sooner you receive your money.

Potential Complications

While the trajectory is positive, several factors could affect the timeline:

Government appeals. The government may still pursue appeals of the CIT's initial refund order or subsequent orders. While CBP is building CAPE, the legal landscape could shift.

System delays. Building a system to process $166 billion in refunds to 330,000 importers is unprecedented. Technical challenges, testing requirements, and the sheer volume of data could push timelines beyond the initial 45-day estimate.

Complex entries. Entries involving antidumping or countervailing duties, suspended liquidations, or other complications will require additional CAPE functionality that is not yet built. If your entries fall into these categories, expect longer processing times.

How Conglobus Can Help

Conglobus International is helping companies navigate the IEEPA refund process from start to finish. Our team reviews your import history to identify IEEPA-specific entries, helps organize the required documentation in the format CBP will require, prepares your claims for submission through the CAPE portal, and monitors the evolving process to keep you informed of deadlines and system updates.

If you are unsure whether your imports were subject to IEEPA tariffs, or if you need help preparing for the CAPE system launch, check your eligibility or contact us directly. We respond to all inquiries within one business day.