CAPE Phases 1, 2 and 3 are live·Phase 3: CIT plaintiffs only·Section 122 expired Jul 24·Updated Oct 23, 2026
ES-003.com

IEEPA refund updates

What changed and when, newest first. Each entry is dated to the event and links its source. Last updated October 8, 2026.

Refund updates by email

A short note when CBP or the courts change something about IEEPA refunds. Free, no spam, and you can reply to any update with a question. Reply STOP to stop.

Get updates by email

  1. Court certifies the Freestyle World class

    The CIT certified a class of importers in Freestyle World v. CBP. There is no refund order for the class yet. Whether the class stops the time limit to sue is not settled.

    Source: CIT Slip Op. 26-123 · Read more

  2. CAPE Phase 3 opens

    Phase 3 opened for importers who sued at the CIT and are covered by its reliquidation order, for entries liquidated more than 80 days ago.

    Source: Baker Tilly, CIT Slip Op. 26-123 · Read more

  3. Interest rates for Q4 2026

    Interest on refunds for October to December 2026 is 7% for non-corporate importers and 6% for corporations. CAPE adds interest automatically.

    Source: 91 FR 60141 · Read more

  4. CBP reports $134.7B in accepted declarations

    In a court declaration CBP reported about 286,000 CAPE declarations and $134.7B accepted, and set the Phase 3 date.

    Source: Reported by C.H. Robinson

  5. Section 122 duties end, Section 301 forced-labor tariffs start

    The Section 122 duties that replaced IEEPA expired and were not renewed. New Section 301 forced-labor tariffs took effect the same day. Neither is part of the IEEPA refund.

    Source: EY, Troutman Pepper, 12 Oct · Read more

  6. Reliquidation orders for CIT plaintiffs

    The CIT ordered reliquidation of entries liquidated more than 80 days ago for importers with pending suits, about 3,700 cases.

    Source: In re Tariffs Collected in Reliance on IEEPA, CIT 26-00219, Reported by Snell & Wilmer

  7. CAPE rejects warehouse entry types 21 and 22

    Warehouse entries are refunded through their withdrawals (types 31, 32, 34, 38), not the warehouse entry itself.

    Source: CSMS #69127837 · Read more

  8. CAPE Phase 2 opens

    Phase 2 opened for entries flagged for reconciliation. CBP announced it on June 23.

    Source: CSMS #69066837, CSMS #69035485 · Read more

  9. Government appeals the universal refund order

    DOJ filed notices of appeal to the Federal Circuit. The appeal is still open.

    Source: Thompson Hine, Holland & Knight

  10. CBP: no refund for finally liquidated entries without an order

    CBP said it will not refund entries past final liquidation unless a court order names the importer. That is why older entries need a suit or the class.

    Source: Sheppard Mullin · Read more

  11. New refund reports, ACH payments from May 12

    CBP described the CAPE reports, including ES-022, and said ACH refunds start May 12.

    Source: CSMS #68536553 · Read more

  12. CAPE Phase 1 goes live

    CAPE opened in ACE at 8:00 AM EDT for unliquidated entries and entries liquidated within the last 80 days. Rules were published on April 13.

    Source: CSMS #68340863 · Read more

  13. CBP announces CAPE

    CBP announced CAPE, a refund tool inside ACE where an importer or its filing broker uploads a list of entries instead of protesting one by one.

    Source: CSMS #68315804 · Read more

  14. Federal Circuit sends the case back to the CIT

    The mandate returned the case to the CIT, which then handled how refunds would work.

    Source: CSMS #68340863

  15. Supreme Court: IEEPA does not allow tariffs

    In Learning Resources, Inc. v. Trump the Supreme Court ruled 6 to 3 that IEEPA does not give the President power to impose tariffs. A 10% Section 122 duty was proclaimed the same day.

    Source: Troutman Pepper · Read more

  16. Updated Form 4811 takes effect

    A notify party gets a refund only if it is on file in the importer's ACE profile and its number is in Box 28 of the 7501.

    Source: CSMS #67648307 · Read more

  17. AGS v. CBP: IEEPA duties cannot be protested

    The CIT held that IEEPA duties are not protestable. The path is a suit under 28 U.S.C. 1581(i), not Form 19.

    Source: AGS v. CBP · Read more

Still stuck? Ask by email

Write to hello@es-003.com. Most questions get a short answer with sources the same day, often within minutes. Questions about one specific CAPE claim go to CBP first: IEEPARefunds@cbp.dhs.gov with the claim number.

Free information site, not a law firm. General information, not legal advice. Please do not send EINs, bank details or documents.

Independent reference, not affiliated with CBP. General information, not legal advice.