U.S. Customs and Border Protection (CBP) has started processing refund requests for certain finally liquidated entries involving tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The reimbursements concern businesses that challenged the duties in court and were subsequently found entitled to refunds by the U.S. Court of International Trade (CIT), according to a court filing dated October 6.
The agency is making the process available through its Consolidated Administration and Processing of Entries (CAPE) portal. Brandon Lord, executive director of CBP’s Trade Programs Directorate, confirmed the development in the filing.
Access to this latest stage remains restricted, however. Only plaintiffs who provided CBP with a valid importer of record (IOR) number on or before July 30, 2026, can currently receive refunds for finally liquidated entries. Businesses that submitted their numbers after that deadline must wait for additional guidance. CBP has not indicated when further instructions will be issued.
As of October 6, the agency had accepted 477 CAPE declarations covering finally liquidated entries for processing. Together, those declarations account for 425,517 entries, according to the court document.
Kelly Nelson, principal consultant and managing director of KPMG Trade & Customs Services, highlighted the development in a LinkedIn post, describing it as another significant milestone in the CAPE process that importers involved in tariff litigation should continue to monitor.
A phased rollout for tariff reimbursements
The processing of refunds for finally liquidated entries represents the latest step in CBP’s gradual expansion of the CAPE system, which began earlier in 2026. The portal is designed to manage reimbursements for duties imposed under the IEEPA, which the U.S. Supreme Court invalidated in February.
CBP had initially planned to introduce this third phase, covering finally liquidated IEEPA entries, by the end of July. Implementation was subsequently postponed until October. The new capability is expected to cover approximately $11.4 billion in tariffs, equivalent to 6.9% of the IEEPA duties at issue.
The Court of International Trade ruled earlier this year that CBP was required to refund duties on entries that had not yet been processed or finalized. The court later broadened its order to include finally liquidated entries, extending the scope of potential reimbursements.
The decision remains subject to legal challenges. The U.S. Department of Justice appealed aspects of the ruling, arguing that the CIT does not have jurisdiction to issue a universal refund order covering all finalized entries. The government also contends that the relief should be limited to the parties that filed lawsuits seeking reimbursement.
The appeal remains pending before the U.S. Court of Appeals for the Federal Circuit, leaving an ongoing legal dispute alongside the administrative rollout.
Billions of dollars in refunds moving through the system
The latest figures indicate the scale of the reimbursement process already underway. According to the most recent filing, as of October 2, CAPE had accepted approximately $136.6 billion in potential and certified refunds for processing.
Of that amount, $126 billion had been forwarded to the U.S. Treasury Department for disbursement.
The launch of processing for finally liquidated entries therefore marks a further expansion of the refund program, although businesses affected by the tariffs must still meet the applicable administrative requirements and follow developments in the ongoing litigation. For importers whose IOR numbers were submitted after the July 30 deadline, the next step remains dependent on additional instructions from CBP.
