Did CBP really pause collection on unpaid IEEPA tariff bills?

Yes. CBP's IEEPA Duty Refunds page was refreshed on May 19–20, 2026 with about 15 FAQ items stamped 'Updated 5/20/2026.' One of those items states directly that 'CBP has paused collection and enforcement actions at this time, such as national sanction and demand on surety, for any bill(s) that include unpaid IEEPA duties.' The pause is at CBP's discretion and applies entry-by-entry to bills that include unpaid IEEPA charges. CBP has not announced an end date for the pause.

Does the pause mean I do not owe the IEEPA duty anymore?

No. The pause is on collection and enforcement actions only — it is not a waiver of the underlying debt. The legal posture changed on February 20, 2026 when the Supreme Court ruled IEEPA does not authorize tariff collection in Learning Resources, Inc. v. Trump, and CBP stopped collecting new IEEPA duties on February 24, 2026 (CSMS #67834313). For prior bills that were issued but never paid, CBP appears to be holding off on sanctions, surety demands, and similar enforcement steps while the refund mechanism runs through CAPE Phase 1 and the DOJ appeal window (through June 6, 2026) closes.

If I have an unpaid IEEPA bill, can I still get a CAPE refund on the same entry?

CBP's May 20 FAQ also clarifies that refunds are netted entry-by-entry against any unpaid debts the importer of record owes CBP. In practical terms: if your CAPE Declaration is accepted for an entry that also carries an unpaid IEEPA bill, the refund computation will offset the unpaid amount before any check or ACH credit issues. You should not assume a clean refund will arrive while a bill is still open on the same entry. Pull the entry summary detail and the bill in ACE before you forecast the refund.

Does the pause apply to all CBP collection activity or just IEEPA?

The pause CBP announced is specifically for bills that include unpaid IEEPA duties. CBP continues to issue and enforce bills for other duty types — Section 232, Section 301, MPF, HMF, AD/CVD, and ordinary duty — on the normal schedule. If you have a bill that mixes IEEPA charges with other duty types, ask the port for a written breakdown so you can see which line items are covered by the pause and which still expect timely payment.

Is there really a CAPE refund scam, and how does CBP say to report it?

Yes. In the same May 20 refresh, CBP added an explicit notice that 'CBP does not charge any fees to importers to receive refunds' and warned importers to be alert to third parties claiming otherwise. CBP directs anyone who suspects a refund-related scam to email Traderelations@cbp.dhs.gov. Filing a CAPE Declaration through ACE is free; legitimate brokers and trade counsel may charge for their services to prepare and file the declaration, but no party can charge a fee to 'receive' a CBP refund on your behalf.

CBP Paused IEEPA Bill Collection: What the May 20 Update Means

CBP refreshed its IEEPA Duty Refunds page on May 19–20, 2026 with roughly 15 FAQ items stamped “Updated 5/20/2026.” Most of the update tightens language that was already in CBP webinars and CSMS messages. One item is genuinely new and matters to any importer still carrying an unpaid IEEPA bill: CBP has paused sanctions and surety demands on bills that include unpaid IEEPA tariff charges. The same refresh added a netting rule for CAPE refunds and an explicit warning about CAPE refund scams.

This post breaks down what changed, what did not, and the operational moves to make this week if you have any open IEEPA-related bills.

CBP pause on IEEPA bill collection sanctions surety demand CAPE refund netting May 2026 update

What CBP Actually Said

From CBP’s IEEPA Duty Refunds FAQ (updated 5/20/2026), three new lines stand out:

Collection pause. “CBP has paused collection and enforcement actions at this time, such as national sanction and demand on surety, for any bill(s) that include unpaid IEEPA duties.”
Refund netting. Refunds will be issued net of any unpaid debts owed to CBP by the importer of record, entry-by-entry.
Scam warning. “CBP does not charge any fees to importers to receive refunds.” Report suspected scams to Traderelations@cbp.dhs.gov.

None of those statements existed on the page in CBP’s earlier refreshes (April 10, April 15, April 17). All three are now official agency policy as of May 20.

What “Pause” Means in Practice

The pause is on enforcement actions, not on the underlying debt. Importers should read it as:

What is paused. National sanctions tied to unpaid IEEPA bills, demands on the surety bond, and similar collection escalations.
What is not paused. The bill itself still exists in ACE. Interest may continue to accrue on the unpaid amount per the normal duty-bill rules. Other duty types on the same bill (Section 232, Section 301, MPF, HMF, AD/CVD, ordinary duty) are not covered by the pause and CBP can continue to collect those.
What is not promised. CBP did not give an end date for the pause and did not say bills will be written off. The pause is an administrative posture during the refund rollout, not a forgiveness.

For an importer who has been quietly worried about a national sanction notice landing during the CAPE filing window, this is real relief. For an importer assuming the bill will quietly disappear, it is not.

How the Netting Rule Affects Your Forecast

The May 20 FAQ now states that CAPE refunds will be issued net of any unpaid debts owed to CBP by the importer of record, on an entry-by-entry basis.

Practically:

If an accepted CAPE Declaration covers an entry that also carries an open IEEPA bill, the refund calculation will reduce the disbursement by the unpaid amount on that same entry before paying anything out.
If the unpaid amount equals or exceeds the refund, the disbursement on that entry can land as zero even though CAPE accepted the declaration.
If you have unpaid bills on entries that are not in your CAPE Declaration, those bills do not net against accepted entries — netting is per entry, not per importer of record.

What to do this week:

Pull a full open-bill report from ACE by importer of record before you finalize a refund forecast. Compare each entry on your CAPE Declaration against any open bills with the same entry number.
For entries with mixed unpaid bills, ask the broker or the port for a written line-item breakdown: how much is IEEPA, how much is everything else.
Update the refund spreadsheet you sent to finance. If you projected gross refunds without netting, the actual ACH credits may come in materially lower.

For the broader timing picture after netting, see Why your CAPE refund may take longer than 60 to 90 days.

The Scam Warning Importers Should Take Seriously

CBP’s new “no fees to receive refunds” language is unusual on a CBP FAQ page. It is there because CBP is hearing from importers that third parties are offering to “obtain” a CAPE refund for a percentage fee.

CBP’s position is simple:

Filing a CAPE Declaration through ACE is free. The portal does not charge a fee for the declaration itself.
Brokers, trade attorneys, and refund-recovery firms can legitimately charge for their professional services (preparing the entry list, reconciling ACE data, advising on protest or CIT options, doing the actual filing on your behalf as the original broker).
No party — broker, attorney, recovery firm, or anyone else — can charge a fee to receive a CBP refund on your behalf. Refunds go through ACH to the IOR or to a properly designated Notify Party (CBP Form 4811) with U.S. banking information on file.

Red flags to watch for in unsolicited refund pitches:

A request to route the refund through the third party’s bank account, with a promise to remit your share later. CBP’s ACH-only refund design now lets you receive funds directly. There is no legitimate operational reason a third party needs to be the receiving bank for a CAPE refund. The “third party bank” pitch is also why we recommend insisting on direct ACH to your own account in our lawyer / broker / recovery firm comparison.
A flat percentage fee tied to “CBP issuing the refund,” rather than to specific professional work product.
Pressure to sign before you have time to verify the firm against state bar listings, the licensed customs broker registry, or any other independent source.
Refusal to put the engagement terms in writing, or to explain what specifically they will do versus what ACE does automatically once a declaration is accepted.

If a pitch fails any of those tests, CBP’s contact for refund-related fraud reports is Traderelations@cbp.dhs.gov.

What Else Changed on the Page

A few of the other May 20 FAQ updates are operational reinforcements rather than new policy, but they matter:

60–90-day window now in CBP’s own FAQ voice. CBP confirmed in the refresh that “valid IEEPA refunds will generally be issued within 60–90 days following acceptance of the CAPE Declaration,” with about 45 of those days as CBP processing time. The window was previously in webinar slides and CSMS messages, not on the FAQ page itself.
Interest authority. CBP now links directly to the January 22, 2026 Federal Register notice as the IRS quarterly rate source under 19 USC § 1505, closing the gap the April 28 CIT order in Princess Awesome v. CBP asked CBP to close. Full methodology in How CBP calculates interest on your IEEPA refund.
CIT not required for clean Phase 1. The “no CIT lawsuit needed for unliquidated entries or entries within the 90-day voluntary reliquidation period” language is still on the page. Decision flow: CAPE, protest, or CIT — which path fits your entries.
Email notifications. CBP repeats that it will not email CAPE updates to importers. Use ACE Reports — ES-022 for CAPE claim status, and REV-603 / REV-613 / REV-615 for refund-stage tracking.

What To Do This Week

If you have any unpaid IEEPA-related bills, work through this short list:

Run an open-bill report in ACE by IOR. Identify every bill that includes an IEEPA line item.
Cross-match against your CAPE Declaration entries. Note which entries appear on both sides.
Recompute the refund forecast with the new netting rule on cross-matched entries. Share the revised number with finance.
Confirm ACH banking information is current and active in ACE for the IOR (or the Notify Party with CBP Form 4811 on file). The pause does not help if a netted refund cannot land. See ACH enrollment is required for your IEEPA refund.
Document the May 20 FAQ language in your internal file. If a port or surety raises a sanction or demand on an IEEPA-line bill during the pause, you have the agency’s own statement to point to.
Watch for the next CIT progress report. CBP’s next progress report to Judge Eaton in the IEEPA refund case is due 12:00 p.m. EDT on May 26, 2026, with a closed settlement conference on May 27. Any new policy posture on the unpaid-bill pause will most likely surface there or in the days that follow.

The Bottom Line

CBP did not forgive unpaid IEEPA bills on May 20, but it did take the most aggressive enforcement steps off the table while CAPE Phase 1 runs. Combined with the new netting rule and the scam warning, the May 20 page refresh shifts the operational picture for importers carrying open IEEPA-line bills: less collection pressure, but a sharper need to reconcile bills against accepted CAPE entries before you forecast a refund, and a clear public-source citation to push back on anyone trying to charge you a fee to receive a refund that ACH delivers for free.

Have unpaid IEEPA bills and an accepted CAPE Declaration?

If your entries are split between accepted CAPE filings and open IEEPA-line bills, the May 20 netting rule changes your refund forecast. A short review can confirm which entries will pay clean, which will net to zero, and which still need a protest or CIT strategy.

Get a Free Assessment

Sources

CBP, IEEPA Duty Refunds FAQ page (https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds), refreshed May 19–20, 2026; FAQ items stamped “Updated 5/20/2026.”
IRS quarterly interest rates, Federal Register notice 2026-01175 (January 22, 2026).
CBP CSMS #67834313 — Cessation of IEEPA tariff collection (February 24, 2026).
April 28, 2026 CIT order in Princess Awesome v. CBP directing CBP to publish updated FAQ guidance.

CAPE Portal Guide is not a law firm, customs broker, or government agency. This article is educational only. For binding advice on unpaid bills, surety posture, or fraud reports, consult a licensed customs attorney.