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The short version
- CBP has accepted about $134.7 billion in IEEPA refunds for processing, and about $122 billion (duties plus interest) has been completed and sent to the Treasury for payment, as of September 11, 2026 (CBP declaration to the Court of International Trade, filed September 15).
- Phase 3 opens October 6, 2026, but only for importers who are plaintiffs in court cases, on finally liquidated entries the court has ordered reliquidated.
- Refunds go only to the importer of record (or a party it named on CBP Form 4811), with interest. CBP does not refund consumers and charges no fees.
- If FedEx, UPS or DHL cleared your package as importer, the money comes back through them, not CBP.
What changed
In February 2026 the Supreme Court ruled the IEEPA tariffs unlawful. CBP refunds them through CAPE (Consolidated Administration and Processing of Entries) in the ACE Portal, in phases:
| Phase | Opened | Covers |
|---|---|---|
| 1 | April 20, 2026 | Unliquidated entries and entries liquidated within the last 80 days |
| 2 | June 29, 2026 | Entries flagged for reconciliation with no reconciliation entry filed yet |
| 3 | October 6, 2026 | Finally liquidated entries filed by court plaintiffs, where the court ordered reliquidation |
Sources: UPS (Phase 1 date) and CBP's September 15, 2026 court declaration (Phases 2 and 3).
CBP says it is still evaluating later phases for other entry types, including entries under an open protest and entries whose liquidation is final. It says valid refunds are "generally issued within 60 - 90 days following acceptance of the CAPE Declaration", paid by ACH, with interest.
What it means for your business
If you were the importer of record on formal entries with IEEPA duties, file a CAPE Declaration in the ACE Portal, or ask your broker to. Entries more than 80 days past liquidation are the hard case: CBP says it "offers no legal guidance on whether a case needs to be filed with the CIT" for entries outside Phase 1. Talk to a customs broker or trade lawyer about those.
If a carrier cleared your shipments:
- FedEx says it "will return any applicable refunds to the parties who originally paid those duties" and runs a portal where you add payment details and check status.
- UPS: no action is needed if UPS was the importer of record. If you were the importer and UPS was your broker, you file in CAPE yourself or pay UPS to file.
- DHL Express says it files Phase 1 claims automatically and estimates another 30 to 90 days after it receives a refund to pay customers (June 10, 2026).
If you are a consumer, CBP does not refund you directly. Any money comes from the carrier or seller who paid the duty.
Illustrative only: if you paid $1,000 of IEEPA duty on an entry, the refund is $1,000 plus interest from the date you paid, at the rate the IRS publishes each quarter.
Who is affected
- Importers of record on 2025 entries that carried IEEPA duties, including Amazon and Etsy sellers who import their own stock.
- Small businesses and shoppers who paid duties to FedEx, UPS or DHL on imported packages.
- Not refunded: Section 301, Section 232 and normal duties, which still apply.
What to do now
- Check your ACE Portal access and the bank (ACH) details in it. No ACE account, no CBP refund.
- List your 2025 entries with IEEPA duties (an ACE report or your broker) and see which phase each one fits.
- If a carrier cleared your goods, use its refund page: the FedEx refund portal, the UPS tariff refunds page or DHL's IEEPA page.
- Ignore anyone who asks for a fee to "release" a refund. CBP charges no fees and warns of scams.
- Once money arrives, rerun your costs in the landed cost calculator. Our China tariff tracker shows the duties that still apply.
Keep track of every change: Every US and Canadian tariff layer on Chinese goods, kept current.
Open the trackerReprice the day your duties change
Our Pricing and Landed Cost Calculator works out cost per unit, margin and break-even price with every duty layer included, so a refund or a new tariff takes seconds to price in. No subscription, no account, your data stays on your device.
General information, not legal, tax or customs advice. Rules change often: check the official sources above or a licensed customs broker before you act. SuanSupply is not affiliated with any government agency or marketplace named here.