IEEPA Tariff Timeline: From Liberation Day to the Supreme Court Ruling (2025–2026)

The IEEPA tariff situation moved quickly, and understanding what happened and when is important for determining where an entry may fall in the refund process. This timeline covers the major developments from the first executive orders in February 2025 through the Supreme Court ruling, the end of IEEPA tariff collection, Court of International Trade refund orders, the launch of CAPE Phase 1 in April 2026 and Phase 2 in June 2026, and the September 2026 confirmation that Phase 3 for qualifying finally liquidated entries filed by CIT plaintiffs will launch October 6, 2026.

Use the timeline to understand how the legal and administrative process developed, where your entries may fall within that sequence, and what the current CAPE status may mean for your situation.

Updated through September 15, 2026.

$134.7B

In refunds accepted for CAPE processing as of Sep 11, 2026

27.2M

Entries accepted for IEEPA duty removal as of Sep 11, 2026

$122B

Sent to Treasury for disbursement as of Sep 11, 2026

ACH Warning

Approximately $1.3 billion in refunds held due to missing bank information

CAPE Phase 1 launched April 20, 2026 and Phase 2 launched June 29, 2026. As of September 11, 2026, 20,184 refunds totaling approximately $1.3 billion have not been transmitted to Treasury because ACH bank account information is missing. If you have not enrolled your bank account in ACE under the ACH Refund Authorization tab, your refund is being held right now. Only the importer of record or the customs broker who originally filed the entries can submit a CAPE Declaration. Post Summary Corrections for IEEPA refunds are prohibited.

Phase 3 launches October 6, 2026 for CIT plaintiffs who submitted a valid IOR number to CBP by July 30, 2026

Phase 2 adds reconciliation entries (entry types 01, 02, and 06 where no type 09 has been filed) subject to the same 80-day liquidation window as Phase 1. CBP confirmed on September 15, 2026 that Phase 3 launches October 6, 2026 and covers finally liquidated entries for CIT plaintiffs. Plaintiffs who submitted a valid IOR number to CBP by July 30, 2026 can file Phase 3 declarations starting October 6. Plaintiffs who submitted after July 30 will receive additional instructions from CBP.

Step 1 — If not done

Set up your ACE Top Account

Having an importer of record number does not automatically give you ACE portal access. You must apply for a Top Account with an Importer sub-account view. This is required to file a CAPE Declaration.

Apply on CBP.gov ↗

Step 2 — If not done

Enroll in ACH electronic refunds

All CBP refunds are electronic only. Add your U.S. bank account under the ACH Refund Authorization tab in your ACE Importer sub-account. As of September 11, 2026, 20,184 refunds totaling $1.3 billion are being held due to missing bank information.

CBP ACH FAQ ↗

Step 3 — File now

Submit your CAPE Declaration

Log into ACE, click More, select CAPE, go to File Uploads, click Upload, download the template, enter your entry numbers, save as CSV, and submit. Each declaration is limited to 9,999 entries. If entry numbers start with zero, insert an apostrophe before the zero to preserve it.

Log into ACE ↗

Step 4 — Phase 3 launches Oct 6, 2026

CIT plaintiffs: prepare to file Phase 3 on October 6

Phase 3 covers finally liquidated entries for CIT plaintiffs who submitted a valid IOR number to CBP by July 30, 2026. Plaintiffs who submitted after July 30 will receive separate CBP instructions. Importers who have not filed suit should consult a trade attorney.

Refund process — where things stand today

Updated September 15, 2026

✓

Supreme Court rules IEEPA tariffs unlawful

Feb 20, 2026

✓

CIT orders refunds; CBP builds CAPE system

Mar 4 through Apr 19, 2026

✓

CAPE Phase 1 launches — filing open for standard entries

Apr 20, 2026

✓

CAPE Phase 2 launches — reconciliation entries now accepted

Jun 29, 2026

▶

Importers filing CAPE Declarations — $122 billion sent to Treasury as of Sep 11, 2026

Now — 27.2 million entries accepted, 19.94 million liquidated or reliquidated

Phase 3 launches October 6, 2026 — CIT plaintiffs with IOR submitted by July 30 can file

CBP confirmed September 15, 2026 — plaintiffs who submitted IOR after July 30 await separate instructions

Current status as of September 15, 2026: CAPE Phase 1 launched April 20, 2026 and Phase 2 launched June 29, 2026. As of September 11, 2026, 286,044 CAPE declarations have been submitted with 201,293 passing file validations. 27.2 million entries have been accepted for IEEPA duty removal, 19.94 million have been liquidated or reliquidated without IEEPA duties, $134.7 billion in refunds have been accepted for processing, and $122 billion has been sent to Treasury. As of September 11, 20,184 refunds totaling $1.3 billion are being held at Treasury due to missing ACH bank information. CBP confirmed on September 15, 2026 that Phase 3 launches October 6, 2026 for CIT plaintiffs who submitted a valid IOR number to CBP by July 30, 2026. Plaintiffs who submitted after July 30 will receive additional instructions from CBP. Only the IOR or the broker who filed the original entries can submit a CAPE Declaration. Post Summary Corrections for IEEPA refunds are prohibited. A closed settlement conference is scheduled for September 16, 2026 at 2:00 p.m. Eastern. CBP email for technical questions: IEEPARefunds@cbp.dhs.gov.

Who receives the refund?

Eligible — direct refund

Importer of Record

The company listed on the customs entry as the importer of record. CBP refunds go exclusively to this party, regardless of who economically bore the tariff cost.

Potentially eligible

Customs brokers as notify party

If a CBP Form 4811 designates a broker as authorized notify party for refunds and that broker is ACH-enrolled, they can receive funds on the importer's behalf. The Form 4811 designation must have been on the original entry.

No direct refund

Buyers who absorbed tariff costs

If you paid higher prices because a supplier passed tariffs through in their pricing, you were not the importer of record. CBP will not refund you directly. Recovery depends on contract terms and negotiation with your supplier.

Not covered

Section 232 and Section 301 payers

Tariffs on steel, aluminum, autos, and China goods imposed under Section 232 or Section 301 were not affected by the IEEPA ruling. Those tariffs remain in force and are not refundable under this decision.

Full timeline — click any event for details

Executive action

Court ruling

Supreme Court

Aftermath / refunds

New tariff regime

Sources: Supreme Court opinion, Learning Resources, Inc. v. Trump (Feb. 20, 2026) · SCOTUSblog · Declaration of Brandon Lord, CIT Case No. 26-01259 (Mar. 6, 2026, Mar. 12, 2026, Mar. 19, 2026, and Mar. 31, 2026) · Order, Atmus Filtration, Inc. v. United States, CIT Case No. 26-01259, Documents 49 and 50 (Mar. 20 and Mar. 27, 2026) · CBP CSMS No. 68315804 (April 2026) · CBP CSMS No. 68340863 (April 13, 2026) · CBP CSMS No. 69035485 (June 23, 2026) · CBP CSMS No. 69066837 (June 2026) · CIT Order, Freestyle World, Inc. v. United States, Court No. 26-01088 (July 17, 2026) · Declaration of Brandon Lord, Freestyle World, Inc. v. United States, Court No. 26-01088, Document 38 (August 25, 2026) · Order, Freestyle World, Inc. v. United States, Court No. 26-01088, Document 40 (August 27, 2026) · Declaration of Brandon Lord, Freestyle World, Inc. v. United States, Court No. 26-01088, Document 50 (September 15, 2026) · BDO Customs and International Trade Services (May 2026) · Thompson Hine SmarTrade (June and July 2026) · Penn Wharton Budget Model · CBP.gov ACE portal and ACH FAQs. For informational purposes only. Not legal or financial advice. For guidance specific to your entries and situation, contact our team directly.