IEEPA Tariff Refund Timeline: Key Dates Every Importer Should Know in 2026
Complete timeline of IEEPA tariff events from February 2025 through CAPE Phase 1 in April 2026, with action deadlines and refund processing milestones.
The IEEPA tariff saga has spanned over a year — from the first Executive Orders in February 2025 to the Supreme Court decision and CAPE system launch in 2026. This timeline consolidates every key date and explains what each event means for your refund.
The Complete IEEPA Tariff Timeline
February 2025 — Tariffs Imposed
| Date | Event | Impact |
|---|---|---|
| Feb 1, 2025 | Executive Order 14193 — 25% tariff on Canadian imports (10% on energy) | All entries from this date forward incurred IEEPA duties |
| Feb 1, 2025 | Executive Order 14194 — 25% tariff on Mexican imports | Same date, separate EO for Mexico |
| Feb 1, 2025 | Executive Order 14195 — 20% additional tariff on Chinese imports | Stacked on top of existing Section 301 tariffs |
What this means for you: Any goods entered from February 1, 2025 onward from these countries may have qualifying IEEPA duties. Check your entry summaries for HTS subheadings 9903.01.25 through 9903.01.70.
March 2025 — Expansion to Venezuelan Oil
| Date | Event | Impact |
|---|---|---|
| Mar 24, 2025 | Executive Order — 25% tariff on countries importing Venezuelan oil | Extended IEEPA tariffs beyond the original three countries |
May 2025 — First Legal Challenge Succeeds
| Date | Event | Impact |
|---|---|---|
| May 28, 2025 | CIT ruling: Genova Pipe v. Lutnick and Noem | U.S. Court of International Trade declares IEEPA tariffs unlawful |
What this means for you: This was the first court ruling against IEEPA tariffs, but it applied only to the parties in the case. The government appealed, and tariffs continued to be collected.
February 2026 — Supreme Court Decision
| Date | Event | Impact |
|---|---|---|
| Feb 20, 2026 | Supreme Court 6-3 decision: Learning Resources, Inc. v. Trump | IEEPA does not authorize the President to impose tariffs |
| Feb 20, 2026 | Executive Order ending all IEEPA tariff actions | Government initiates process to stop collection and refund duties |
| Feb 24, 2026 | CSMS #67834313 — CBP stops collecting IEEPA tariffs | No new IEEPA duties assessed on entries from this date forward |
What this means for you: The Supreme Court ruling made it clear that all IEEPA tariffs collected from February 2025 through February 2026 are eligible for refund. The question is how — which is where CAPE comes in.
April 2026 — CAPE Phase 1 Launches
| Date | Event | Impact |
|---|---|---|
| Apr 10, 2026 | CSMS #68315804 introduces CAPE deployment | CBP confirms CAPE will consolidate IEEPA refunds including interest |
| Apr 13, 2026 | CSMS #68340863 publishes Phase 1 filing rules | Importers get the first detailed validation and workflow guidance |
| Apr 20, 2026 | CAPE Phase 1 goes live in ACE Portal | Importers can begin filing declarations for qualifying entries |
What this means for you: You can now submit CAPE declarations through ACE for unliquidated and recently liquidated entries, but you need to follow the April 13 rules around filer ownership, CSV format, protests, and other validation blockers. See our complete guide →
Critical Deadlines You Need to Know
CAPE Declaration Filing
There is currently no announced deadline for filing CAPE declarations under Phase 1. However, CBP may set one in future guidance. File as soon as your data is ready.
Protest Filing — 180 Days from Liquidation
For entries that have been liquidated, you have 180 days from the liquidation date to file a protest under 19 USC § 1514. This is a hard deadline — miss it and you lose the right to protest.
| If your entry liquidated on… | Your protest deadline is… |
|---|---|
| January 15, 2026 | July 14, 2026 |
| February 20, 2026 | August 19, 2026 |
| March 1, 2026 | August 28, 2026 |
| April 20, 2026 | October 17, 2026 |
Important: Even if you’re filing a CAPE declaration, trade law experts recommend also filing a protest as a backup strategy. Learn why →
CIT Lawsuit — 2 Years from Protest Denial
If your protest is denied, you have 180 days to file a lawsuit in the Court of International Trade. This may be the only option for finally liquidated entries excluded from CAPE Phase 1.
Refund Processing Timeline (After CAPE Filing)
Once you submit a CAPE declaration, here’s what to expect:
| Phase | Duration | What Happens |
|---|---|---|
| Declaration Review | Up to 45 days | CBP verifies entries, checks for exclusions, validates data |
| Liquidation/Reliquidation | Immediate – 45 days | Unliquidated entries are liquidated; recently liquidated entries are reliquidated on the next business day |
| Refund Calculation | Included in review | Refunds consolidated by IOR + liquidation date |
| ACH Disbursement | 15-45 days after approval | Lump sum deposited to your registered ACH refund account |
| Total Estimated | 60-90 days | From declaration acceptance to funds in your account |
Note: The 60-90 day estimate is CBP’s guidance, not a binding commitment. Complex cases or high volumes may take longer.
What’s Coming Next?
Future CAPE Phases
CBP has indicated that future phases will expand eligibility to cover:
- Finally liquidated entries (liquidated more than 80 days ago)
- Entries currently blocked or slowed in Phase 1 (such as drawback, reconciliation, certain AD/CVD scenarios, and older liquidations)
- Additional processing improvements
No dates have been announced for Phase 2 or beyond. We’ll update this timeline as CBP releases new guidance.
Ongoing Litigation
Several cases are still making their way through the courts:
- Nintendo of America Inc. v. U.S. Department of the Treasury — Filed March 2026, seeking recovery of IEEPA duties through judicial process
- Various protest appeals and CIT filings by importers whose entries fall outside CAPE Phase 1
Your Action Plan for 2026
| When | What to Do |
|---|---|
| Now | Verify your ACE Portal access and set up ACH refund account |
| Now | Identify all qualifying entries (HTS 9903.01.25 – 9903.01.70) |
| Now | Check your eligibility → |
| Before filing | Prepare your CSV data file (see our CSV guide →) |
| When ready | File CAPE declaration through ACE Portal |
| Within 180 days of liquidation | File protests as backup for all liquidated entries |
| If needed | Consult with trade law professionals about CIT litigation |
Stay Informed
The IEEPA refund process is evolving. We track every CBP announcement, CSMS message, and court ruling that affects importers.
Update — April 30, 2026: New Milestones to Add to Your Timeline
Ten days into Phase 1, three additional dates belong on every importer’s calendar:
| Date | Event | Why it matters |
|---|---|---|
| Apr 28, 2026 | CIT Judge Eaton’s deadline for CBP to file a CAPE Phase 1 progress report | Confirms ongoing judicial oversight; the report itself may surface additional Phase 1 metrics |
| Apr 28, 2026 | CIT order publishes first hard CAPE numbers: ~21% of IEEPA entries accepted, ~3% liquidated | First publicly verifiable measurement of Phase 1 throughput; reaffirms reconciliation entries are excluded — and IEEPA duties are reportedly still being collected on reconciliation adjustments |
| Apr 29, 2026 | NCBFAA “From IEEPA to CAPE” educational webinar | Industry-wide signal that broker capacity is being trained up specifically for CAPE |
| ~May 11, 2026 | Earliest possible date for first IEEPA refund ACH disbursements (per Sandler Travis & Rosenberg, April 29; now court-cited in the April 28 order) | This is materially earlier than the 60-90 day total most importers were planning around. ACH must be live before then to be in the first wave. |
| May 12, 2026 — 12:00 p.m. EDT | CBP’s next CAPE Phase 1 progress report due to the CIT (closed settlement conference 2:00 p.m. same day) | Next opportunity for fresh Phase 1 metrics and a likely catalyst for guidance updates (including the unresolved refund-interest-rate question) |
Full breakdown of the April 28 order with the original PDFs: What the April 28 CIT order reveals about CAPE Phase 1 →. Full breakdown of the May 11 acceleration: First IEEPA refund payments could land May 11 — what to confirm before they do →.
May 2026 — Refunds Flow, CIT Escalates
| Date | Event | Impact |
|---|---|---|
| May 11, 2026 | First IEEPA refund disbursements issued via Treasury ACH | $35.46B anticipated on 8.3M liquidated entries; 1,880 refunds stuck on missing ACH |
| May 12, 2026 | CBP files second CAPE progress report with CIT | Confirms first-wave numbers; DOJ appeal window set at June 6 |
| May 19–20, 2026 | CBP refreshes IEEPA Duty Refunds FAQ (~15 items “Updated 5/20/2026”) | Confirms 60–90 day refund window, pauses sanctions on unpaid IEEPA bills, warns on refund scams |
| May 26, 2026 | CBP files third CAPE progress report | $20.6B certified to Treasury; ~$85B total pipeline; 15.8M entries accepted; average 18-day turnaround; ~33% of declarations fail file validation |
| May 27, 2026 | CIT Judge Eaton issues show cause order + orders CBP Commissioner to appear in person | CBP must respond by June 4; Commissioner Scott ordered to appear June 9; judge “particularly concerned” about millions of finally-liquidated informal entries |
| June 4, 2026 | CBP show-cause response due | Will signal whether CBP plans to expand refund scope to finally liquidated entries |
| June 6, 2026 | DOJ deadline to appeal CIT refund order | Appeal would pause further judicial expansion but not claw back issued refunds |
| June 9, 2026 | CIT hearing — CBP Commissioner ordered to appear in person | May determine Phase 2 scope and timeline for finally liquidated entries |
Get a Free Assessment → to have a trade law professional review your specific situation and recommend the best refund strategy.