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

The IEEPA tariff situation moved faster than almost any trade policy in recent memory and keeping track of what happened and when matters for understanding your refund rights. This timeline covers every major event from the first executive orders in February 2025 through the Supreme Court ruling, the end of tariff collection, the Court of International Trade refund orders, the launch of CAPE Phase 1 in April 2026, Phase 2 in June 2026, and the ongoing litigation over finally liquidated entries. Use it to understand where your entries fall in the legal and administrative sequence and what the current status means for your specific situation. Updated through June 29, 2026.

$85B

In refunds accepted for CAPE processing as of May 2026

15.1M

Entries accepted for IEEPA duty removal through CAPE as of May 2026

Phase 2

Launched June 29, 2026 covering reconciliation entries

CAPE Is Live

File your CAPE Declaration now if you have not already

CAPE Phase 1 launched April 20, 2026 and Phase 2 launched June 29, 2026. If you have not yet filed your CAPE Declaration, log into your ACE portal, click the More tab, select CAPE, go to File Uploads, and upload your CSV of entry numbers. Only the importer of record or the customs broker who originally filed the entries can submit. Post Summary Corrections for IEEPA refunds are prohibited.

As of May 2026, over 4,000 consolidated refunds are being held at Treasury due to missing ACH bank information — if your enrollment is not complete, act now

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. Phase 3 is expected by end of July 2026 but scope has not been confirmed. Finally liquidated entries remain the subject of active litigation.

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. Over 4,000 refunds are currently held at Treasury 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 — If liquidated

Check your 80-day CAPE window

Entries within 80 days of liquidation can go on a CAPE Declaration. Entries between 80 and 180 days past liquidation may still be protested but consult your broker first since open protests block CAPE. Finally liquidated entries are subject to ongoing litigation.

Refund process — where things stand today

Updated June 29, 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 — refunds being processed and sent to Treasury

Now — $20.6 billion sent to Treasury as of May 2026

Phase 3 expected — scope unconfirmed; finally liquidated entries remain in litigation

Expected end of July 2026

Current status as of June 29, 2026: CAPE Phase 1 launched April 20, 2026 and Phase 2 launched today June 29, 2026. As of May 2026, over 15 million entries have been accepted for IEEPA duty removal, approximately $85 billion in refunds have been accepted for processing, and $20.6 billion has been sent to Treasury. Over 4,000 consolidated refunds are being held at Treasury due to missing ACH banking information. Only the IOR or the broker who filed the original entries can submit a CAPE Declaration. Post Summary Corrections for IEEPA refunds are prohibited. For unliquidated standard entries, refunds are generally expected within 60 to 90 days of CAPE Declaration acceptance. Phase 3 is expected by end of July 2026 but scope has not been confirmed. The situation for finally liquidated entries is actively contested in court. 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) · BDO Customs and International Trade Services (May 26, 2026) · Thompson Hine SmarTrade (June 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.