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May 11 Is Here in 3 Days. Where's Your Refund?

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3 Days Until Refunds79% Stuck

3 days until first refunds arrive. The 80-day window is still running.

79% of CAPE submissions are stuck or rejected. The June 7 government appeal deadline is closing in. If you haven’t filed yet, every day costs you. Calculate your refund in 60 seconds.

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On May 11-12, 2026, the first IEEPA tariff refunds will appear in importer bank accounts. CBS News confirmed it. U.S. Court of International Trade Judge Richard Eaton confirmed it in his April 28 progress report. For the importers who filed clean and have ACH banking set up, the money is about to land. For the 79% of importers whose CAPE submissions are still stuck or rejected, May 11 is a public reminder that they're behind. And the June 7 government appeal deadline — the date by which a Federal Circuit stay could land — is closing in.

The 3-Day Countdown

On May 11-12, 2026, the first IEEPA tariff refunds will appear in importer bank accounts. Confirmed by CBS News and U.S. Court of International Trade Judge Richard Eaton in his April 28 court filing.

For the importers who filed early, filed clean, and have ACH banking set up, that money is about to arrive. Real cash. Wired to real bank accounts. Plus statutory interest from the original entry dates.

For the 79% of importers whose CAPE submissions are still stuck or rejected — May 11 is not a payday. It is a public reminder that they're behind.

The numbers from Judge Eaton's progress report on April 28:

  • 75,306 CAPE declarations filed
  • 47,315 properly accepted (62%)
  • Only 21% have moved to refund stage
  • 1.74 million entries cleared validations
  • 2.1 million entries rejected outright

Translation: most importers who rushed to file still have their refunds tied up in validation queues or rejected for data errors. The clean filers get paid. Everyone else waits — or learns that their entries aged out of the 80-day Phase 1 window entirely.

The June 7 Appeal Threat Is Closing In

The government's deadline to appeal the Court of International Trade's nationwide IEEPA refund order runs through approximately June 7, 2026. Trade legal analysts widely expect an appeal to the Federal Circuit. A successful appeal could result in a stay that delays additional refund payments while the appeal is pending.

The rule that matters: refunds processed and paid before any stay is granted are unlikely to be clawed back. Refunds still in queue when a stay drops are exposed.

That puts every importer with a pending or stuck claim on a 30-day clock. May 11-12 is the first wave of payments. The May 12 court progress report will reveal the second wave's processing volume. By early June, the safest payment window starts to close.

For importers reading the calendar:

  • May 11-12: first refunds land in bank accounts
  • May 12: CBP files updated court progress report — second wave numbers public
  • ~June 7: government appeal deadline — Federal Circuit stay possible after this
  • Post-stay scenario: refunds in queue may be paused for months

Acceptance is what matters. A clean, accepted CAPE declaration with ACH ready is the safest position. A stuck or rejected submission with the 80-day window still running and June 7 approaching is the worst position.

The Data Error Problem Nobody Is Solving

The biggest reason 79% of submissions are stuck is data accuracy at the line-item level.

CAPE compares your submission to CBP's original entry summary records line by line. If your HTS code, entered value, quantity, or country of origin doesn't match exactly, the entry triggers "Unable to Calculate Duty" or similar errors.

For importers with a few hundred entries, this is manageable. Pull the CF 7501 forms, compare line by line, fix any discrepancies, resubmit.

For importers with thousands of entries spread across multiple brokers, multiple HTS codes, and multiple countries — this is a nightmare. One Vietnam apparel importer in our recent client base had 1,847 entries to reconcile. They tried to file in-house, got 312 rejections, and had to redo the entire submission three weeks later.

The math on getting it wrong:

  • $5 million in expected refunds
  • 15% rejection rate on first submission = $750,000 in entries kicked back to validation queue
  • Resubmission takes 2-3 weeks of broker time
  • Some of those entries age out of the 80-day window before resubmission accepted
  • Net loss: $200,000-$400,000 in refunds that move to Phase 2 (no announced date)

For refunds over $250,000, the cost of getting it wrong exceeds the cost of getting professional help.

What to Do This Weekend

If your refund is under $50,000:
- Use CBP's standard process — file through your customs broker
- Make sure ACH banking is enrolled in ACE
- Watch for May 11 deposits

If your refund is between $50,000 and $250,000:
- Get a pre-filing review of your data
- Verify ACH and ACE setup
- File before May 12 if possible

If your refund is over $250,000:
- Stop trying to DIY this
- Get professional review of every entry before submission
- The cost of professional filing is fractional compared to the risk of rejection at scale

Key Takeaway

May 11-12 is the cutover from anticipation to evidence. The clean filers find out their math was right when ACH deposits hit. The 79% with stuck or rejected submissions find out they're running out of 80-day window time. The May 12 court progress report will reveal the second wave's numbers, and the June 7 government appeal deadline will close the safest payment window. For refunds above $250,000, professional pre-filing review costs a fraction of the risk of getting the resubmission wrong at scale — file clean, get accepted, get paid before any potential Federal Circuit stay.

For refunds over $250,000, our network handles every step

Master Plan Accounting and Frost Law AZ. Pre-filing entry audit. CSV preparation. ACE submission. Status monitoring. The trade attorneys work on contingency. Free 15-minute consultation.

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Frequently Asked Questions

When will the first IEEPA tariff refunds be paid?
CBP confirmed in its April 28 progress report to U.S. Court of International Trade Judge Richard Eaton that the first IEEPA refund payments will land in importer bank accounts on May 11-12, 2026. Only declarations that have already cleared declaration-level and entry-level validation are positioned for that first wave. As of April 26, only 21% of declarations had been accepted and only 3% of entries had entered the refund stage, so the first wave will be relatively narrow. Refunds are issued via ACH only — CBP has not issued paper checks since February 6.
What is the May 12 court progress report?
Judge Richard Eaton ordered CBP to file an updated CAPE refund progress report by May 12, 2026. The report will reveal updated declaration counts, acceptance and rejection rates, the volume of entries that have moved into the refund stage, and whether the May 11 first-payment estimate held. It is the second public progress report after the April 28 filing. The May 12 numbers are also the last public dataset before the June 7 government appeal deadline — they will be a major signal of whether CBP's processing capacity is keeping up with the inbound queue and whether Phase 2 has been scheduled.
What happens if my CAPE submission is still stuck on May 11?
Stuck submissions stay in the queue. They do not lose Phase 1 eligibility just because May 11 has passed — but the 80-day window from each entry's liquidation date keeps running. Most stuck entries fall into one of three buckets: validation failures (HTS, value, or quantity mismatches), categorical exclusions (reconciliation, drawback, USMCA duty-deferral, AD/CVD-pending), or access issues (incomplete ACE configuration, missing ACH enrollment). The fix is to identify the exact rejection reason in ACE, correct the underlying data, and resubmit before any individual entry ages out of the 80-day window.
Why are most CAPE refund claims rejected?
CBP confirmed a 15% rejection rate on initial CAPE filings since April 20, and roughly 19% of all submitted entries (2.1 million) were rejected outright at validation. The four main causes are: line-level data mismatch between submission and CBP's entry summary records (HTS code, entered value, quantity, country of origin); ineligible entry types (reconciliation, drawback, USMCA duty-deferral, TIB, AD/CVD-pending, surety-paid); missing ACH enrollment in the Importer sub-account; and authorization issues (the wrong party trying to file — must be original IOR or original filing broker). Most are diagnosable from the ACE rejection report and fixable, but the 80-day window keeps running while you fix them.
Should I wait for Phase 2 if my submission was rejected?
Generally no. Phase 2 has no announced date and will likely cover entries that fell outside the 80-day liquidation window or fell into categorical exclusions like reconciliation entries. If your rejection was a data error or an access issue, you should fix it and resubmit during Phase 1 — Phase 1 acceptance is the safest path to a refund paid before any Federal Circuit stay. Only entries that are categorically excluded from Phase 1 (reconciliation, drawback, AD/CVD-pending, surety-paid, etc.) are clear candidates to wait for Phase 2.
How long is the IEEPA refund 80-day window?
Phase 1 of the CAPE refund process covers unliquidated entries and entries within 80 days of liquidation as of the April 20 portal opening. The 80-day window runs from each individual entry's liquidation date — so importers with entries liquidated in early February 2026 have already crossed the cutoff, while entries liquidated in late March or April are still in window. There is no single 'Phase 1 deadline' — the window expires entry-by-entry. Importers with stuck or rejected submissions need to identify which of their entries are closest to aging out and prioritize fixes on those first.

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