April 30, 2026

IEEPA Tariff Refunds: First Payments Expected, But  Process Remains Early-Stage

Summary

A new Reuters report indicates that the first IEEPA tariff refunds under the CAPE system are expected around May 11. While this marks an important milestone, current data confirms that the refund process remains in its early, phased rollout.

Key data points:

• ~21% of entries have been accepted into CAPE

• Only ~3% have reached the refund/payment stage

• ~1.74 million entries are in the pipeline (as of April 26)

• Total scope: ~$166B across ~53M entries /~330,000 importers

• Process is under active oversight by Richard K. Eaton at the U.S. Court of International Trade

• Refund process stems from the February 20 ruling by the U.S. Supreme Court invalidating IEEPA tariffs

What This Means for Members

1. Initial payments are limited
The May 11 timing reflects early Phase 1 CAPE cases only—primarily:

• Unliquidated or recently liquidated entries

• Importers already positioned with:

  • ACE access

  • ACH refund setup

  • Submitted entry data

This is not a broad payout event. It is the first wave.

2. CAPE is functioning—but not complete

• Acceptance of 21% of entries confirms the system is active

• The majority (~79%) of entries remain outside Phase 1

Members should expect additional phases to address remaining entries.

3. Payment timing will lag submissions
With only ~3% of entries at the refund stage:

• Processing through CAPE does not immediately result in payment

• Delays are occurring in:

  • Liquidation/reliquidation

  • Treasury disbursement

Members should plan for timing gaps between submission and receipt.

4. Scale is significant—and progressing
The inclusion of ~1.74 million entries in the pipeline indicates:

• CAPE is operating at meaningful scale

• CBP is processing entries in grouped, high-volume workflows

This supports longer-term throughput, even if early stages are gradual.

5. Judicial oversight remains active
Ongoing involvement from the Court provides:

• Transparency into progress

• Continued pressure on agency execution

This reduces the risk of delay due to administrative or policy factors.

What Remains Unclear

Members should note that key details are still developing:

• Full eligibility scope for Phase 1

• Timing for:

  • Final-liquidated entries

  • Protested entries

• Whether refund timing will vary by importer or entry type

Member Takeaways

• Act now to ensure positioning

  • Confirm ACE access

  • Verify ACH refund setup

  • Prepare CAPE-ready entry data

• Expect phased recovery

  • Early entries may move first

  • Broader recovery will follow over time

• Prioritize data accuracy

  • Entry-level precision is critical for processing

  • Internal tracking tools (e.g., TRT frameworks) are strongly recommended

Bottom Line

CAPE is active and refunds are beginning. However, the process is phased, uneven, and still in early execution.

Members should interpret current developments as the start of recovery—not completion—and take steps now to ensure full participation in upcoming phases.

This information is believed to be accurate as of the date above and is provided for informational purposes only. It does not constitute legal, financial, or business advice. Members should independently verify details and consult appropriate advisors before taking action.