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 order, and the current status of CBP’s CAPE refund system as of March 2026. Use it to understand where your entries fall in the legal and administrative sequence and what the current status means for your specific situation.$166B
Estimated total owed in IEEPA tariff refunds plus interest
330,000+
Importers with potentially eligible entries across 53 million total entries
<10%
Of eligible importers have registered to receive electronic refunds
Action Required
Most importers cannot receive their refund yet
CBP has confirmed that refunds will be issued electronically only. As of February 6, 2026, paper checks are no longer issued. To receive a refund, importers must be registered in CBP's ACE portal with ACH banking details on file. As of March 26, 2026, 26,664 importers of record have completed this setup, covering 78% of entries and approximately $120 billion in IEEPA duties. However a significant number of smaller importers have still not completed enrollment. If your account is not configured when refunds begin processing, CBP will place your refund in reject status.
As of March 26, 2026, 26,664 importers have completed ACH enrollment — if you are not one of them, act nowCBP is building a new refund portal called CAPE (Consolidated Administration and Processing of Entries) expected to launch around mid-April 2026. You cannot file yet but you can prepare now so you are ready the moment the system opens.
Step 1 — Do this now
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 do anything else.
Apply on CBP.gov ↗Step 2 — Do this now
Enroll in ACH electronic refunds
Once you have portal access, add your U.S. bank account information under the ACH Refund Authorization tab. Your bank routing number must support FedACH payments.
CBP ACH FAQ ↗Step 3 — Prepare now
Gather your entry records for CAPE
When CAPE launches, you will upload a CSV file of IEEPA-tariffed entry summary numbers through a new tab in your ACE portal. Ask your customs broker to compile all entry numbers, IEEPA duty amounts, and liquidation statuses for shipments from February 4, 2025 through February 24, 2026. Note: CAPE Phase 1 will not cover entries with Suspended, Extended, or Under Review status, entries subject to antidumping or countervailing duties, warehouse withdrawals, or drawback claim entries.
Step 4 — Consider
Protest liquidated entries
If your entries have already liquidated, consult a trade attorney about filing a Protest within 180 days of liquidation to preserve your refund rights. The litigation deadline at the Court of International Trade is no earlier than February 3, 2027.
Refund process — where things stand today
Updated March 31, 2026
✓
Supreme Court rules IEEPA tariffs unlawful
Feb 20, 2026
✓
CIT orders refunds; CBP reveals CAPE system — 45-day build
Mar 4–6, 2026
▶
CBP building ACE refund portal — importers prepare now
Now through mid-April 2026
4
Importers upload CAPE Declaration CSV; Treasury issues electronic refunds
Mid-April 2026 and beyond
Current status: CBP filed its most detailed CAPE update yet on March 31, 2026. As of March 30, CAPE component completion stands at: Claim Portal (85%), Mass Processing (60%), Review and Liquidation (80%), and Refund (75%). Phase 1 has been expanded to accept Suspended, Extended, Under Review, AD/CVD, and warehouse entries — CAPE will remove IEEPA HTS codes from these entries but will not immediately process refunds, which will follow in the normal liquidation course. Despite the March 27 court order, finally liquidated entries will NOT be in Phase 1 and will be addressed in a subsequent phase. Phase 1 covers approximately 63% of all IEEPA entries. CBP will take up to 45 days to review and liquidate entries after accepting a CAPE Declaration. As of March 26, 26,664 importers have completed ACH enrollment covering 78% of entries and approximately $120 billion in duties.
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.
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
