IEEPA Tariff Refunds: The Dates That Decide Whether You Get Paid

The money is real, but it is not automatic. One date, the day your entry liquidated, decides which route you are on.

What is being refunded

The Supreme Court struck down the IEEPA tariffs on 20 February 2026. US Customs and Border Protection had collected about $166 billion of them on more than 53 million entries made between February 2025 and February 2026, and is paying them back through CAPE, a tool inside its ACE system.

The three phases

• Phase 1, open since 20 April 2026: entries that have not liquidated, or that liquidated within the last 80 days.
• Phase 2, open since 29 June 2026: entries flagged for reconciliation.
• Phase 3, open since 6 October 2026: entries whose liquidation is final, but only for importers who are plaintiffs in cases before the Court of International Trade.

Why liquidation decides everything

Customs liquidates a formal entry, fixing the final duty, usually about 314 days after the goods are entered. The importer then has 180 days to protest. If that window passes without a protest, the liquidation is final and the only route left is the court.

That is why the earliest IEEPA entries, from early 2025, are the most at risk: many liquidated long before CAPE opened.

What is still contested

As of late October 2026, the government has appealed the refund orders to the Federal Circuit, and a motion to certify a class of importers is pending. Either could widen or narrow who is paid. Importers who are not plaintiffs, and whose entries are close to finality, should take advice on whether to file their own case before the two-year limit runs.

What to do

1. Pull a list of your IEEPA-period entries with their entry and liquidation dates.
2. Claim through CAPE for every entry that is unliquidated or inside the 80-day window.
3. Protest within 180 days of liquidation where CAPE does not cover the entry.
4. Talk to a licensed customs broker or trade counsel about entries that are finally liquidated.

This is general information, not legal advice. Zentria Flow's refund guide shows which route applies to an entry from its liquidation date: zentriaflow.com/ieepa-tariff-refund.