CAPE Refund Pipeline Tops $100 Billion Sent to Treasury

CBP’s CAPE refund program crossed a major milestone in August. The agency’s August 4, 2026 progress declaration reported that approximately $100 billion in IEEPA refunds had been completed and sent to the U.S. Treasury for disbursement as of July 31, 2026. The latest September 15 declaration puts that figure at about $122 billion as of September 11; that does not mean all importers have received payment. If you paid IEEPA tariffs between February 2025 and February 2026, get a free assessment to see where your refund stands in this pipeline.

What the $100 Billion Milestone Means

The $100 billion figure is the strongest signal yet that the CAPE system is the workhorse for IEEPA refunds — not just a pilot. CBP has now certified and transmitted more than $100 billion in refunds (duties plus interest) to Treasury for disbursement, and Treasury’s accounting system confirms the certified refunds are being regularly dispersed.

But a large pipeline is not the same as every importer getting paid. Two gaps stand out in the August 4 report, and both are actionable for you:

1. ACH information is missing for 19,726 refunds (about $1.6 billion). This is roughly double the 9,837 held refunds reported on July 10. If you have not verified ACH refund banking in ACE, your approved refund can sit at the disbursement step. See our ACH enrollment guide.
2. 5.02 million entries failed entry-level validation. The most common reasons are entries past CBP’s 90-day reliquidation authority, entries without a Chapter 99 IEEPA HTS line, and entries already filed on a prior CAPE declaration. See our validation error guide.

The Numbers Behind the Report

CBP Executive Director Brandon Lord’s declaration reports the following as of 3:00 p.m. EDT on July 31, 2026:

The most common file-validation failures remain importer-of-record or filer mismatches, entry-number problems, and CSV files that do not match the published template. The 7-step CAPE guide walks through each validation check.

ACH Backlog Doubles: 19,726 Refunds Await Banking Information

The sharp jump in ACH-blocked refunds is the single most important caution in the August 4 report. In about three weeks, the number of refunds held because importers have not provided ACH account information went from 9,837 (as of July 10) to 19,726 refunds totaling approximately $1.6 billion (as of July 31).

Missing ACH information is not a CAPE rejection — it is a disbursement hold. The refund may be fully processed and certified, but it will not be transmitted to Treasury until the importer of record (or its authorized CBP Form 4811 designee) has valid ACH refund banking on file in ACE. The Court of International Trade again urged CAPE declaration filers to make sure ACH information has been provided.

Check yours now: log in to ACE, open the Importer Account view, and confirm the ACH Refund Authorization tab has valid banking information for whoever will receive the refund. See our ACE account setup guide if you are not sure where to look.

The Reliquidation Order Has Now Been Entered

The August 5, 2026 CIT order confirms that Judge Eaton’s July 17 reliquidation order has now been entered in more than 3,700 IEEPA cases. That order directs CBP to reliquidate, without regard to IEEPA duties, all entries liquidated for more than 80 days on which plaintiffs made estimated IEEPA deposits — including finally liquidated entries that CAPE previously could not touch.

Two boundaries matter:

• It applies only to plaintiffs in the court-assigned cases, who must submit importer-of-record identification numbers to CBP. Importers who did not file a CIT lawsuit are not covered.
• It is not a general Phase 3 launch. No public Phase 3 filing lane has been announced. For non-litigant importers, the Freestyle World class-certification motion remains the principal open question; the August 19 oral argument has passed and no written ruling was verified in the available public materials.

Read the full reliquidation order analysis and the finally liquidated CIT path guide for the plaintiffs-vs-non-litigants decision framework.

August 25 Report Confirms the Phase 3 Delay

CBP’s August 25 declaration replaces the earlier secondary-only Phase 3 reporting with a primary-source explanation:

• Phase 3 is temporarily delayed while CBP builds validations for finally liquidated entries.
• The scope is plaintiff-specific: Phase 3 covers entries filed by plaintiffs for which the court has ordered reliquidation.
• Phases 1 and 2 remain operational and are not affected by the delay.
• No new deployment date was provided.

Source: August 25 Lord Declaration, ECF No. 38. Until CBP and the court publish operating instructions, do not treat Phase 3 as available; continue using Phase 1 and Phase 2 where eligible and protect protest deadlines.

Track every checkpoint on the CAPE Update Tracker and in the full timeline.

What Importers Should Do Now

1. Verify ACH information today. CBP’s September 15 declaration reports 20,184 refunds totaling about $1.3 billion not transmitted because ACH information was missing as of September 11. Confirm the ACH Refund Authorization tab in ACE for the actual refund recipient. See the ACH enrollment guide.
2. File Phase 1 and Phase 2-eligible entries now. Phase 3 is planned for October 6 but is not live yet. Clean unliquidated entries and reconciliation-flagged entries (Entry Types 01, 02, 06 without a Type 09 on file) remain the available path where eligible. See the 7-step guide.
3. Protect protest deadlines. The 180-day protest window runs independently of CAPE. File protective protests on entries still inside the window. See the protest filing guide.
4. Get counsel review for finally liquidated entries. If you are a plaintiff in a court-assigned case, watch for CBP’s instructions to counsel and prepare your IOR identification numbers. If you are a non-litigant with material finally liquidated exposure, ask trade counsel whether an individual 28 USC 1581(i) complaint is appropriate. Request a free assessment and we will connect you with vetted trade counsel.

Update — August 23, 2026: Phase 3 Delayed Without a New Opening Date

• An August 19 report at IEEPATariffRefunds.info says CBP told the CIT it could not roll out CAPE Phase 3 as planned and could not provide an opening date. A separate August 21 report from Diaz Trade Law describes Phase 3 as delayed until further notice and cites International Trade Today.
• These are secondary reports, not an official CBP deployment CSMS. CBP’s public IEEPA page still lists Phase 1 and Phase 2 as the active phases. Importers should not wait for an unconfirmed Phase 3 lane: file protective protests within the 180-day window and obtain counsel review for material finally liquidated exposure.

Update — August 27, 2026: $106.6B Sent and $1.7B Awaits ACH

• CBP reported approximately $132.5 billion accepted for CAPE processing and approximately $106.6 billion completed, certified, and sent to Treasury as of August 21. Source: August 25 Lord Declaration, ECF No. 38.
• The accepted declarations covered 26.4 million entries, and 18.76 million had been liquidated or reliquidated without IEEPA duties.
• 22,170 refunds totaling approximately $1.7 billion had not been transmitted because ACH information was missing. Importers should verify the banking record for the IOR or authorized Form 4811 designee.
• Phase 3 is temporarily delayed and limited to finally liquidated plaintiff entries covered by court-ordered reliquidation. Eligible Phase 1 and Phase 2 filings should continue, with protective protests used where the 180-day window remains open.

Update — September 22, 2026: $122 Billion Sent to Treasury; Limited Phase 3 Planned

• CBP’s September 15 Lord Declaration, ECF No. 50 reports $134.7 billion accepted for CAPE processing and approximately $122 billion certified and sent to Treasury as of September 11. This is not a count of dollars received by every importer.
• The same declaration reports 20,184 refunds totaling about $1.3 billion not transmitted because ACH information was missing. It plans Phase 3 deployment October 6 for qualifying court-covered plaintiffs who supplied a valid IOR number by July 30; see the eligibility checklist.
• The September 17 CIT order, ECF No. 52 sets an October 6 progress report and October 7 conference, not a general non-plaintiff filing lane. Continue eligible CAPE filings and preserve protest rights where available.

The CAPE pipeline has passed $100 billion, but your refund still depends on your ACH setup and entry posture. Get a free assessment and a vetted trade-law professional will review your refund status and recommend next steps.

Source Notes

Sources: CBP Executive Director Brandon Lord, Declaration, August 25, 2026 (ECF No. 38); Declaration, August 4, 2026 (ECF No. 24); CIT, Freestyle World, Inc. v. United States, Court No. 26-01088, August 5, 2026 order (ECF No. 25); CIT, July 17, 2026 reliquidation order (ECF No. 52). CAPE Portal Guide is not a law firm, customs broker, or government agency.