The International Emergency Economic Powers Act (IEEPA) was invoked by the Trump administration beginning in 2025 to impose broad tariffs on virtually all U.S. trading partners. These tariffs were struck down by the Supreme Court on February 20, and more than $175 Billion in importer refunds remain in dispute.
CBP has launched Phase 1 of the CAPE refund module in ACE allowing importers to request IEEPA Tariff Refunds. Meanwhile, the Trade waits to see if the DOJ will file an appeal against the underlying CIT order. We continue to issue updates (see “News” below):
News in IEEPA Refunds
7/15/26: CIT Confirms CAPE Phase 3 IEEPA Refunds Across 3,700 Cases
6/29/26: CBP Outlines Process to Re-Activate a Deactivated Importer of Record (IOR) in ACE
6/24/26: FedEx to Return Approximately $800 Million in IEEPA Tariff Refunds to Customers Beginning in August
6/23/26: CBP: Only Recon-Flagged Entries Without a Filed Recon Entry Accepted in Next CAPE Phase
6/2/26: DOJ Notifies Court It Will Appeal CIT's Universal IEEPA Refund Order
4/27/26: No IEEPA Refunds Have Yet Been Issued, However, Consumer Class Actions Are Already Here
4/21/26: CAPE Phase One IEEPA Refunds Move Forward
4/13/26: As CAPE Nears Completion, Polls Emerge on the Impact of Tariff Policy
4/10/26: April 20 Launch: CBP's CAPE System Promises Consolidated IEEPA Refunds
4/7/26: Atmus Filtration Dismisses Lead IEEPA Refund Suit
3/28/26: CIT Expands Paused IEEPA Tariff Refund Order to Include Finally Liquidated Entries
3/24/26: Early Liquidation Risk Across Entry Types
3/20/26: CIT Expands IEEPA Refund Order to Cover Brazil and India Tariffs
3/18/26: Why the Supreme Court's Mandate Is Potentially Important for IEEPA Refund Strategy
3/17/26: SCOTUS Mandate Likely to Issue in the Near Future
3/13/26: CBP Building New CAPE System to Process IEEPA Tariff Refunds at Scale
3/12/26: Section 122 Tariffs Now Under Legal Challenge at the CIT
3/11/26: Five Days of Silence: Will the Administration Appeal the IEEPA Refund Order?
3/10/26: No Refunds Have Been Issued, But Consumer Class Actions Are Already Here
3/6/26: CIT Hearing Update: CBP Says It Needs 45 Days to Process IEEPA Tariff Refunds