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Master Plan Tariffs Tool

IEEPA Tariff Refund Tracker (2026)

Data updated September 11, 2026 · Sector-level estimates from public CBP/court sources — not legal or tax advice

After the Supreme Court struck down the IEEPA tariffs on February 20, 2026, roughly $166 billion in collected duties became refundable to about 330,000 importers across ~53 million entries. CBP is returning the money through its CAPE process (live since April 20, 2026). As of September 11, 2026, about $134.7 billion had entered CAPE for processing and roughly $122 billion had been certified and sent to Treasury for disbursement (including interest) — about 73% of the pool now paid.
~$166 billion
Total IEEPA duties collected
The full refundable pool, across ~330,000 importers and ~53 million entries (April 2025–Feb 2026).
~$134.7 billion
Entered CAPE for processing
Potential and certified refunds that had entered CBP's CAPE platform as of 3pm ET September 11, 2026 (27.2 million entries), per CBP's September 15 declaration to the Court of International Trade — a subset of the pool, still being validated.
~$122 billion
Repaid to importers
Certified and sent to Treasury for disbursement as of September 11, 2026, per CBP's September 15 declaration to the CIT — about 73% of the pool, up from $106.6 billion on August 21. (CBP's ACH-banking-detail sub-figure, $1.7 billion stuck as of August 21, was not restated in the September filing.)
~330,000
Importers owed
Importers of Record that paid IEEPA duties and are eligible to file.
~53 million
Entries involved
Customs entries that carried IEEPA reciprocal or fentanyl tariffs.
6–7%
Statutory interest
Refunds accrue interest — 7% for individuals, 6% for corporations — compounded daily under 19 CFR 24.36.

How Much of the Refund Pool Has Been Paid?

Collected (the full pool)$166B
CAPE claims accepted$134.7B
Repaid to importers$122B

Bars are proportional to the ~$166B collected. Figures as of September 11, 2026; they move as CBP processes claims.

CAPE Refund Phases

PhaseTimingCovers
Phase 1LIVELaunched April 20, 2026Unliquidated entries and entries within 80 days of liquidation — the cleanest, most automatable cases.
Phase 2LIVELive — opened June 29, 2026Reconciliation entries (types 01/02/06 flagged for a not-yet-filed type 09, limited to unliquidated or within-80-days entries) and antidumping/countervailing-duty (AD/CVD) entries.
Phase 3UPCOMINGConfirmed — deploys October 6, 2026 (per Sept 15, 2026 CBP declaration)Finally-liquidated entries (~$11.4B). Originally targeted for late July, then delayed August 25 to add validations; CBP's September 15 declaration to the CIT confirmed an October 6, 2026 launch — but access is limited to importers who are plaintiffs in a pending CIT case and who submitted their IOR number to CBP by July 30, 2026. Importers who haven't sued still have no administrative path to a refund on finally liquidated entries. Government's appeal of the CIT's universal-refund orders remains pending at the Federal Circuit (opening brief filed Aug 10); a class-certification motion seeks to cover the rest.

What Is and Isn’t Refundable

Refundable

  • IEEPA reciprocal tariffs (the country-specific 'Liberation Day' rates)
  • IEEPA fentanyl/trafficking tariffs (China, Canada, Mexico)

Not Refundable

  • Section 232 tariffs (steel, aluminum, copper, autos) — not struck down
  • Section 301 tariffs (China) — not struck down
  • Section 122 (the 10% replacement tariff, Feb 24–Jul 24, 2026) — expired July 24 and replaced by the Section 301 forced-labor tariff, which is not refundable
  • Standard MFN base duties

Refund Timeline

Feb 4, 2025
China fentanyl IEEPA tariffs take effect — start of the refund-eligible window for China.
Mar 4, 2025
Canada/Mexico trafficking IEEPA tariffs take effect (eligible window start for those origins).
Apr 2025
Reciprocal ('Liberation Day') IEEPA tariffs take effect (10%–49% by country).
Feb 20, 2026
Supreme Court rules 6-3 (Learning Resources v. Trump / V.O.S. Selections) that IEEPA does not authorize tariffs — duties become refundable.
Feb 24, 2026
10% Section 122 tariff replaces IEEPA (a separate authority; not refundable).
Apr 20, 2026
CBP launches CAPE Phase 1 in the ACE Portal.
May 11–12, 2026
First ACH refund payments hit importer bank accounts.
Jun 29, 2026
CAPE Phase 2 opens (reconciliation + AD/CVD entries).
Jul 13, 2026
Treasury data: $49.1B refunded in June alone — more than double the month's $23.6B in new tariff collections; refund wave widens the FY2026 deficit for the first time.
Jul 10, 2026
CBP court declaration: $86.3B repaid to importers, $121.75B accepted for processing — over half the pool now paid.
Jul 24, 2026
Section 122 tariff expired by operation of law at its 150-day statutory limit; Congress did not act to extend it.
Late Jul 2026
CAPE Phase 3 originally expected (finally liquidated entries, ~$11.4B) — eligibility contested in the government's Federal Circuit appeal.
Aug 4, 2026
CBP declaration (Freestyle World v. United States): $100B certified and sent to Treasury for disbursement — about 60% of the $166B pool; $128.68B had entered CAPE as of July 31.
Aug 10, 2026
DOJ files its opening Federal Circuit brief seeking to vacate the CIT's order directing reliquidation of finally-liquidated IEEPA entries.
Aug 21, 2026
CBP update to CIT: $132.5B accepted for CAPE processing (26.4M entries), $106.6B certified and sent to Treasury — about 64% of the $166B pool.
Aug 25, 2026
CBP tells CIT it has delayed CAPE Phase 3 deployment (finally liquidated entries) to add validations; no new launch date announced.
Sep 15, 2026
CBP declaration to CIT: as of Sept 11, $134.7B accepted for CAPE processing (27.2M entries), $122B certified and sent to Treasury — about 73% of the $166B pool. Same filing confirms CAPE Phase 3 (finally liquidated entries) will deploy October 6, 2026, limited to CIT plaintiffs who submitted IOR numbers by July 30, 2026.

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Tariffs Tool. “IEEPA Tariff Refund Tracker (2026).” Updated September 11, 2026. https://www.tariffstool.com/tariff-refund-tracker

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