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
CBP deployed the first Phase 2 lane for reconciliation-flagged entries on June 29, 2026. Other categories still require separate guidance, including already-filed Entry Type 09 reconciliations, drawback, open protests, and finally liquidated entries.
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 |
| May 29, 2026 | DOJ signals appeal and stay request | Davis Wright Tremaine reports the government moved to appeal and pause universal refund relief |
| June 4, 2026 | CBP show-cause response due | The response feeds into whether the CIT can force broader refund compliance while the appeal proceeds |
| June 2, 2026 | DOJ files appeal | The government challenged the CIT’s universal-refund order as applied to finally liquidated entries held by non-litigants |
| June 9, 2026 | CIT refund status hearing | CBP confirmed June 29 Phase 2 reconciliation functionality and late-July Phase 3 programming |
| June 16, 2026 | CBP updates ACE/TAO guidance | New account webforms, automated TAO reactivation, TAO lookup, and CAPE contact routing |
| June 29, 2026 | Phase 2 deployed | Initial lane accepts eligible reconciliation-flagged Entry Types 01, 02, and 06 without an Entry Type 09 already on file |
| June 9, 2026 | CIT hearing — CBP Commissioner ordered to appear in person | May clarify how the CIT will supervise refunds during the appeal posture |
| July 1, 2026 | CBP files updated Lord Declaration with CIT | $104.29B in potential and certified refunds accepted for CAPE processing; $71.06B completed and sent to Treasury; 8,384 refunds blocked by missing ACH |
| July 2, 2026 | CIT order confirms Phase 2 launch and next progress report | Court notes Phase 2 launched June 29 and orders another CAPE progress report by July 13 |
| July 2, 2026 | CSMS #69127837 clarifies warehouse filings | Type 21/22 warehouse entries no longer accepted after July 7; Type 31/32/34/38 warehouse withdrawals continue to be accepted |
| July 8, 2026 | CBP Federal Register notice (Doc. 2026-13771) | Confirms rejected CAPE CSVs must be corrected and resubmitted (9,999-entry limit); refunds held without ACH; broker filers need ACE notify-party relationship; narrow paper-check waiver under 31 CFR Part 208 |
| July 13, 2026 | CBP Lord Declaration (ECF 45) | As of July 10: $121.75B accepted for CAPE processing, $86.3B sent to Treasury, 9,837 refunds ACH-blocked, 229,609 declarations submitted (161,792 passed), 24.4M entries accepted, 16.74M liquidated IEEPA-free, 4.77M failed entry-level validation |
| July 15, 2026 | CIT order (ECF 46) | Phase 3 still in development; future reliquidation order for ~3,700 IEEPA cases; open-protest functionality in development; Euro-Notions intends to dismiss; Freestyle World (26-01088) to become lead case with class-certification motion pending; next report due Aug 4, settlement conference Aug 5 |
| July 16, 2026 | Euro-Notions notice of dismissal (ECF 48); Zonos amicus response (ECF 47) | Lead plaintiff voluntarily dismisses under Rule 41(a)(1)(A)(i); Zonos explains postal-stream Qualified Party duty collection under EO 14324 |
| July 17, 2026 | CIT order (ECF 49) | Judge Eaton denies Hausfeld LLP et al. motion for leave to file amicus brief (ECF 36) |
Update — June 8, 2026: June 9 CIT Hearing Imminent
The June 9, 2026 CIT hearing is the proceeding where CBP Commissioner Rodney Scott was ordered to appear in person. Key context:
- CBP’s show-cause response was due June 4; CBP filed its response by the deadline (the filing is not yet publicly available).
- DOJ appealed the CIT refund order before the June 6 deadline, seeking a stay of the universal refund requirement. The appeal means the CIT’s authority to compel broader refunds could be contested in higher courts.
- The June 9 hearing will be the first time a CBP Commissioner has been ordered to personally appear before the CIT on IEEPA refunds. Judge Eaton is expected to question the pace of refunds and CBP’s position on finally liquidated entries.
- What to watch for: Whether the CIT issues an order expanding refunds beyond Phase 1, and whether the government seeks an emergency stay from the Federal Circuit.
Operationally, this does not stop clean CAPE filing. Phase 2 reconciliation functionality is now live for the initial no-Type-09 lane, warehouse withdrawals have their own July 2026 filing rule, and Phase 3 programming is targeted for late July. Older liquidations remain deadline-sensitive: file protective protests within 180 days where available, and ask trade counsel whether finally liquidated entries require a Court of International Trade complaint.
Get a Free Assessment → to have a trade law professional review your specific situation and recommend the best refund strategy.