IEEPA Tariff Refund Update: CBP Reports $35.46B in Refunds

CBP’s latest IEEPA tariff refund update shows that the refund process is moving, but it also shows how much work may still remain for importers.

In a May 12 update to the U.S. Court of International Trade, Customs and Border Protection reported that CAPE declarations accepted so far cover 15,123,221 entries with IEEPA duties that passed entry-specific validations and were accepted for removal of those duties. Of those accepted entries, 8,338,081 entries have already been liquidated or reliquidated without IEEPA duties.

CBP said the anticipated refund and interest amount tied to those 8.3 million liquidated or reliquidated entries is approximately $35.46 billion. That figure includes both the principal refund amount and associated interest due after removal of the IEEPA duties.

This is a major update for U.S. importers, but it is not the end of the refund process. Reuters has reported that more than 330,000 importers paid IEEPA tariffs across roughly 53 million shipments, with total refunds potentially reaching about $166 billion. Based on CBP’s accepted CAPE filing count of 15.1 million entries, only about 28.5% of the affected shipment universe has passed this filing-validation milestone so far. That means roughly 37.9 million entries, or about 71.5%, may still be outside the accepted-entry count reflected in the latest update. Applied proportionally to the importer universe, as many as approximately 236,000 importers could still have refund opportunities that are not yet fully processed. This is an estimate based on entry progress, not a CBP-published count of remaining importers.

What CBP’s Latest CAPE Filing Numbers Mean

CBP’s latest update centers on CAPE, the Consolidated Administration and Processing of Entries process being used to manage IEEPA duty refunds. CAPE was developed to process large volumes of affected entries through ACE, rather than requiring CBP to handle every refund manually on an entry-by-entry basis. Several trade law firms and logistics providers have described CAPE as a mechanism that allows an importer of record or its authorized customs broker to submit a consolidated declaration covering many affected entries. CBP can then validate the filing, remove the applicable IEEPA duties, recalculate the entry, and process refunds with interest where appropriate.

The numbers in CBP’s May 12 update are important because they show movement through multiple stages of the process. First, more than 15.1 million entries have passed file and entry-specific validations. Second, 8.3 million of those entries have already moved to liquidation or reliquidation without IEEPA duties. Third, CBP has identified about $35.46 billion in anticipated refunds and interest tied to the processed entries.

Those milestones are not all the same. An accepted CAPE declaration means the entry data passed CBP’s validation process for removal of IEEPA duties. Liquidation or reliquidation means CBP has recalculated the entry without those duties. Refund transmission is a later step, and payment can still depend on account details, Treasury processing, and the importer’s ACH setup.

CBP also reported that 1,880 consolidated refunds had not been transmitted to Treasury because ACH account information had not been provided by the importer of record or its authorized CBP Form 4811 designee. That detail matters. Even when entries are accepted and refunds are calculated, payment can still be delayed if CBP cannot confirm where the money should be sent.

The IEEPA Refund Opportunity Is Still Large

The latest CBP filing confirms that billions of dollars are already moving through the refund process. But the broader opportunity remains much larger.

Reuters has reported that more than 330,000 importers paid IEEPA tariffs on about 53 million shipments, and that the government may ultimately need to refund up to $166 billion. CBP’s current accepted CAPE declarations cover 15.1 million entries, which is substantial, but it still represents only part of the affected universe.

The practical implication is straightforward: importers should not assume that the refund process is complete simply because refunds have started. Some companies are already receiving payments, while others may still need to confirm eligibility, submit CAPE declarations, review liquidation status, supply ACH information, or preserve refund rights through protests where applicable. Reuters has reported that companies including Oshkosh and Basic Fun have already received partial reimbursements, but other importers are still waiting or working through the process.

For importers, this is not just a headline about government processing. It is an operational and compliance issue. Companies need to know which entries included IEEPA duties, whether those entries are liquidated or unliquidated, whether they fall into the current CAPE phase, whether refund payment information is on file, and whether additional action is needed to preserve claims.

Why Importers Should File Now Instead of Waiting

Importers should not treat IEEPA refunds as automatic.

The current refund process requires action through CAPE for eligible entries. UPS summarizes that IEEPA refunds must be requested through CBP’s CAPE process in ACE, and that only the importer of record or an authorized customs broker may submit a CAPE declaration on eligible entries.

That means waiting can create avoidable risk. Entry status can change. Liquidation windows can matter. ACH information can delay payment. Older entries may require a different procedural strategy than newer unliquidated entries. Some entries may also involve complexity related to reconciliation, drawback, protests, antidumping or countervailing duty issues, or other factors that may affect when and how the refund is handled.

Phase One is also limited. UPS states that Phase One only handles certain unliquidated entries and certain entries within 80 days of liquidation. Other legal and trade summaries similarly describe Phase One as focused on unliquidated entries and recently liquidated entries, with more complex entries expected to be addressed in later phases.

That distinction matters for importers that assume every paid IEEPA duty is being processed the same way at the same time. The process is phased. Some entries are simpler. Some require later handling. Some may require a protest or other action to preserve rights. Reuters’ legal analysis has emphasized that importers should maintain records, file timely CAPE declarations, and continue to evaluate protest needs for older liquidated entries.

The safest approach is to review entries now, not after deadlines, liquidation milestones, or documentation gaps become harder to fix.

Can Importers File IEEPA Refunds Themselves?

In some cases, yes. Importers of record can participate directly if they have the necessary access, data, and procedural understanding. But the process is not just a general refund request. It is a customs filing tied to entry numbers, entry summaries, duty lines, liquidation status, ACE/CAPE access, importer-of-record authority, ACH refund details, and CBP validation.

CAPE declarations are submitted through ACE, and the process requires accurate entry-level data. According to UPS, only the importer of record or an authorized customs broker may submit a CAPE declaration for eligible entries.

For importers with a small number of straightforward entries, direct filing may be manageable if the company has the right internal trade compliance resources. But many importers do not have complete entry data readily available, do not know whether all entries are eligible under the current CAPE phase, or do not know whether certain entries require a different strategy because of liquidation status or other customs activity.

The issue is not whether an importer can try to file. The issue is whether the importer can identify the full refund opportunity, file correctly, avoid preventable delays, and preserve rights where the entry does not fit cleanly into the current phase.

Why a Licensed Customs Broker Is Better Equipped to Handle IEEPA Refunds

Freight Right is a licensed customs broker, which matters in this process.

A licensed customs broker is already equipped to work with the systems, records, and customs procedures that determine whether an IEEPA refund is properly filed and processed. IEEPA refund filing is connected to customs business: entry summaries, duty payment history, importer-of-record data, ACE access, liquidation or reliquidation status, and communications with CBP.

The value of using a licensed customs broker is not simply administrative. It is procedural and strategic.

A broker can help determine which entries included IEEPA duties, which entries fall within the current CAPE phase, which entries may need to be handled later, and which entries may require a protest or additional review. A broker can also help importers avoid incomplete submissions, incorrect entry lists, missing ACH details, or assumptions that cause refunds to be delayed.

This is especially important because CBP’s May 12 update shows that payment logistics still matter. The fact that 1,880 consolidated refunds had not been transmitted to Treasury because ACH account information was missing is a reminder that refund eligibility and refund payment are not the same thing. Importers need both the filing path and the payment details to be correct.

Freight Right can help importers:

• Identify entries with IEEPA duty exposure.

• Review entry summaries and duty payment records.

• Determine whether entries are eligible under the current CAPE phase.

• Prepare and submit CAPE declarations where authorized.

• Review liquidation and reliquidation status.

• Identify entries that may require protests or later-phase handling.

• Coordinate importer-of-record and ACH information issues.

• Help prevent refund delays caused by incomplete records or incorrect assumptions.

For importers that paid IEEPA duties, the goal is not just to file something. The goal is to recover the refund they are entitled to while reducing avoidable compliance and processing risk.

What Documents Importers Should Gather

Importers that want to pursue IEEPA refunds should start by collecting the records needed to evaluate eligibility and support the claim. These may include:

• CBP Form 7501 entry summaries.

• Commercial invoices.

• Packing lists.

• Bills of lading or airway bills.

• Duty payment records.

• Broker statements.

• Importer-of-record information.

• ACH refund payment details.

• Liquidation notices.

• Any protests, post-summary corrections, reconciliation filings, drawback activity, or AD/CVD-related records.

Recordkeeping is especially important because refund strategy depends on entry-level facts. Reuters’ legal analysis has emphasized the need for importers to maintain robust records, file timely CAPE declarations, and preserve rights where protests may be required.

An importer that does not know which entries carried IEEPA duties, which entries have liquidated, or which broker filed the original entries may have a refund opportunity but still be unprepared to act efficiently.

What Happens After a CAPE Declaration Is Accepted?

After a CAPE declaration is accepted, CBP validates the entries, removes applicable IEEPA duties where appropriate, recalculates the duties, and processes liquidation or reliquidation. From there, eligible refunds are consolidated and transmitted for payment, subject to ACH confirmation and other processing requirements.

CBP’s public IEEPA duty refund guidance states that importers and authorized brokers should generally anticipate valid IEEPA refunds within 60 to 90 days after acceptance of the CAPE declaration.

Steptoe’s analysis of the CAPE mechanism also states that CBP estimated unliquidated entry summaries would be set to liquidate 45 days from CAPE declaration acceptance, with refunds generally expected within 60 to 90 days unless the declaration requires further review.

That timeline should be treated as a general expectation, not a guarantee. Entries requiring additional CBP review, entries outside the current phase, entries with missing ACH information, or entries with other customs complications may take longer.

Freight Right Can Help Importers File Their IEEPA Tariff Refunds

The latest CBP update confirms that IEEPA tariff refunds are real, substantial, and already moving through the system. It also confirms that the process is not finished.

CBP has accepted CAPE declarations covering more than 15.1 million entries, and 8.3 million entries have already been liquidated or reliquidated without IEEPA duties. The anticipated refunds and interest tied to those processed entries total approximately $35.46 billion. But Reuters’ reporting indicates the full universe is much larger: more than 330,000 importers paid IEEPA tariffs across about 53 million shipments.

For importers, the message is clear. If your company paid IEEPA duties, now is the time to review your entries, confirm your filing path, and determine whether action is needed.

Freight Right is a licensed customs broker that can help importers evaluate and file eligible IEEPA tariff refund claims. Our team can review your entry data, identify eligible refund opportunities, prepare filings, and help you move through the CAPE process with the customs expertise required to reduce avoidable delays.

Importers can attempt to manage the process themselves, but CAPE filings are not a general customer-service request. They are customs filings tied to entry records, liquidation status, importer authority, duty calculations, and CBP processing rules. A licensed customs broker is better positioned to help importers act quickly, file correctly, and preserve refund opportunities.

If your company paid IEEPA tariffs, Freight Right can help you determine what may be recoverable and what steps should be taken now.