Every U.S. importer who paid IEEPA reciprocal or fentanyl tariffs between February 1, 2025 and February 20, 2026 is potentially owed a refund. CBP's CAPE Phase 1 portal opened on April 20, 2026. This page tracks where the pipeline stands today — what's filed, what's been paid, and what changed in the last 24 hours.
At a glance
Day 8 of CAPE Phase 1: filings ramping, no refunds disbursed yet, ACH backlog is now the binding constraint
The submission pipeline is functional and importers are filing. CBP's published 60–90 day target means the first ACH credits won't land before late June 2026 even on perfectly-clean Day-1 submissions. The headline risk for importers right now is administrative, not legal: CBP Form 400 (ACH refund enrolment) has a 5–15 business day processing time, and any importer who hasn't filed it is queueing their refund into suspense regardless of how clean their CAPE submission is.
Where things stand today
The legal question is settled
The Supreme Court's ruling in Learning Resources v. Trump struck down the IEEPA tariff regime in late 2025. Executive Order 14389 ("Termination of IEEPA Tariff Authorities"), issued February 23, 2026, formally rescinded the nine implementing executive orders that had imposed reciprocal and fentanyl-related IEEPA tariffs from February 2025 onwards. The refundable window therefore covers entries with deposit dates from February 1, 2025 through February 20, 2026.
The legal basis for the refunds is no longer disputed. What remains is operational execution by CBP and by importers.
CAPE Phase 1 is the active filing channel
CBP launched the CBP ACE Portal Entry Refund (CAPE) module on April 20, 2026, per CSMS #68340863. Phase 1 covers entries that are either unliquidated, or that liquidated within 80 days before April 20, 2026 — roughly January 30, 2026 onwards. Penn-Wharton's modelling suggests this captures about 63% of the eligible refundable pool; the remaining ~37% sits in entries that finally-liquidated earlier and is waiting on either Phase 2 or protective CF-19 protests under 19 USC § 1514.
No refunds have been disbursed yet
CBP's published target is 60–90 calendar days from CSV acceptance to ACH credit. With Phase 1 only 8 days old, no Phase 1 submission has reached the disbursement stage yet. Statutory interest accrues at the IRS underpayment rate plus 3% (currently a ~6.5% blended rate) from the original duty deposit date through the refund date — meaning a typical August 2025 entry refunded in late June 2026 will earn roughly 11 months of interest on the principal.
The ACH enrolment trap is the biggest near-term risk
Per CBP's launch-week notice, fewer than 10% of affected importers had ACH refund enrolment active on April 20, 2026. Without ACH enrolment, an accepted CAPE refund queues in suspense indefinitely — even if the underlying submission is clean. CBP Form 400 ("Application for ACH Refund") takes 5–15 business days to process. Every day an importer delays filing Form 400 is a day their refund won't land, regardless of how fast CAPE accepts the underlying claim.
Phase 2 has no published date
CAPE Phase 2 — covering entries that finally-liquidated more than 80 days before the April 20 launch — has no published live date as of today. The practitioner consensus is that large importers should file protective CF-19 protests under 19 CFR Part 174 on every entry liquidated between August 2025 and January 2026, to preserve statutory rights regardless of when (or whether) Phase 2 launches.
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What U.S. importers should do right now
- File CBP Form 400 today. ACH enrolment is the binding constraint. Without it, no refund will actually pay out — regardless of how clean your CAPE submission is. cbp.gov/trade/automated/ach.
- Pull your ACE ITRAC for Feb 1, 2025 – Feb 20, 2026. This is CBP's canonical view of every entry filed under your importer-of-record number, and it is the source of truth for refund work. See how to read your ACE ITRAC report for IEEPA refund eligibility.
- Identify your refund pathway per entry. Unliquidated & IEEPA-only → CAPE Phase 1. Unliquidated & multiple corrections → PSC. Liquidated <180 days → Protest (CF-19). Older liquidations → CIT or wait for Phase 2.
- Watch for the EO 14289 stacking trap. Entries that stacked IEEPA on top of Section 232 had the IEEPA portion suppressed under EO 14289 (April 29, 2025, never rescinded). Your ITRAC will show the 9903.01.xx code as declared, but duty actually collected on that line may be zero. Refund is computed off collected dollars, not declared rates.
- File CAPE for Phase 1 entries; file protective CF-19 protests for Phase 2 entries. Don't wait for Phase 2 to be announced. The 180-day protest window under 19 USC § 1514 starts at liquidation and runs out regardless of CBP's Phase 2 timing.
Recent updates
Most recent first. We update this log every weekday morning (US Eastern time).
Frequently asked
How many CAPE claims have been filed so far?
CBP has not published a public running tally of CAPE submissions, and the practitioner reporting we track is anecdotal. The data points we have: CBP rate-limited CAPE to 10,000 lines per importer per day on launch, suggesting expected volume; six rejection patterns account for ~80% of returns in the first week, suggesting non-trivial submission counts. We will update this section the moment CBP publishes aggregate metrics.
How much has actually been refunded?
Zero confirmed disbursements as of today. CBP's published 60–90 day target from CSV acceptance to ACH credit means the first cohort lands no earlier than late June 2026, even on Day-1 submissions. Once disbursements begin, this tracker will publish the running total as CBP reports it.
What if my entry liquidated more than 180 days ago?
The 19 USC § 1514 protest window has closed for those entries. The remaining options are (a) wait for CAPE Phase 2 (no published date) or (b) file a Court of International Trade challenge if the dollar amount justifies litigation. Most importers in this position are waiting for Phase 2 rather than litigating.
Can my customs broker file CAPE on my behalf?
Yes. CAPE is a self-service module inside the ACE Secure Portal, and any importer with ACE access can upload directly — but a broker holding the ACE relationship can also upload on your filer code. Either way, the refund pays to the IOR's ACH account. Make sure the broker's Power of Attorney covers post-entry refund work; some older POAs do not.
I paid IEEPA on entries where my supplier was the IOR (DDP). Can I claim?
No. CAPE refunds flow only to the Importer of Record on the original CBP Form 7501. If a foreign supplier shipped DDP and was the IOR, the refund is theirs. Your only path is commercial — renegotiate the DDP price retrospectively. If the supplier has no U.S. ACH enrolment, the refund can sit pending indefinitely even when claimed.
How is statutory interest calculated on the refund?
Interest accrues at the IRS underpayment rate plus 3 percentage points (currently a blended ~6.5%) from the original duty deposit date through the refund credit date. A $1.8M refund on entries averaging an August 2025 deposit, refunded in late June 2026, earns roughly $108k in interest. Interest is paid automatically with the principal — no separate filing required.
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Related reading
Primary sources
- U.S. Customs & Border Protection — IEEPA Duty Refunds (CAPE) Program FAQ
- CBP CSMS #68340863 — CAPE CSV technical specification (April 18, 2026)
- Federal Register — Executive Order 14389, "Termination of IEEPA Tariff Authorities" (February 23, 2026)
- CBP — Automated Clearing House (ACH) Refund Program (Form 400)
- 19 USC § 1514 — Protest of decisions of the Customs Service · 19 CFR Part 174 — Protest procedures
- Penn-Wharton Budget Model — IEEPA refundable-universe estimate ($166–179B)