IEEPA Tariff Refunds: $122B Certified, 6.1M Entries Rejected. How Ecommerce Importers Claim Theirs as Phase 3 Opens Oct 6

Take two sellers who each paid $3,200 in tariffs on identical shipments of phone cases last spring. (They are a made-up pair, used here to show how the rules work.) One is in line for a refund from the US government. The other is not, and no form she files will change that. The only difference is whose name was on the customs paperwork.

The refunds are already flowing. The tariffs in question were the IEEPA tariffs, the emergency duties the Supreme Court struck down in February. According to CBP's September 15 declaration to the Court of International Trade, about $122 billion had been certified and sent to the Treasury for payment by September 11. The same filing shows 6.1 million entries (an entry is the customs filing for one shipment) failed CBP's checks. A third phase of claims opens on October 6, but only for importers who sued.

Whether you see any of it depends on one question: were you the importer of record? That is the business legally responsible for the goods at the border, and CBP (US Customs and Border Protection) refunds only that business. If it was you, you claim through a CBP tool called CAPE, and the money arrives as a direct bank deposit. If a supplier, courier or dropshipper imported for you, the refund goes to them, and your job is to get it passed back.

This post walks you through where the claim process stands, why entries get rejected, how to file, and how to book the money against each product once it lands. We covered the ruling itself in June in what to do after SCOTUS killed the tariffs you already paid.

Where the tariff refund process stands

On February 20, 2026, in Learning Resources, Inc. v. Trump, the Supreme Court held 6–3 that IEEPA does not authorize the President to impose tariffs. That covered the fentanyl tariffs on Canada, Mexico and China and the "reciprocal" tariffs on nearly everyone else.

CBP built its refund tool, CAPE (Consolidated Administration and Processing of Entries), inside ACE. ACE is the online portal importers and customs brokers already use to file with CBP. CAPE went live on April 20. A second phase followed on June 29 for entries flagged for reconciliation, meaning their final figures were still open for adjustment.

Two terms in CBP's numbers need a quick translation. Liquidation is CBP's final calculation of the duty owed on an entry. Reliquidation reopens that calculation, and it is how most refunds get paid. These are the figures CBP gave the court:

Two days later, the court's September 17 order in Freestyle World v. CBP singled out the $1.3 billion held for missing ACH details. (ACH is the US bank-transfer network, and CBP pays refunds no other way.) It noted that importers who can't get into ACE can get help from a customs broker with a valid power of attorney. CBP's next progress report is due October 6.

Why 6.1 million entries were rejected

CBP rejects claims at two levels, and the fix is different for each.

File-level rejections kill the whole declaration. CBP lists three main causes: the importer of record doesn't match the filer, entry numbers are the wrong length or don't exist, or the CSV doesn't match the ACE template. These are clerical errors. Correct the file and submit it again.

Entry-level rejections remove single entries from an otherwise valid declaration. The 6.1 million came from this group, and the causes matter more:

• Past the 90-day reliquidation window. CBP can reliquidate an entry on its own only within 90 days of liquidation, so CAPE accepts entries liquidated within the preceding 80 days. Older entries are outside what CBP can fix on its own. See the Phase 3 section below.
• No Chapter 99 IEEPA line. Chapter 99 is the part of the US tariff schedule where temporary extra duties like IEEPA are listed, and each one shows up as its own line on the entry. If the entry never carried an IEEPA line, there is no IEEPA duty to refund. This often means you listed the wrong entries.
• Already claimed. Someone, often your broker, already put it on an earlier declaration.

According to CBP's IEEPA Duty Refunds page, you receive the rejection reasons and can file a new declaration for entries that weren't previously submitted. Resubmitting a duplicate just produces another rejection.

Who gets the tariff refund: the importer-of-record test

CBP pays the importer of record (IOR). It does not ask who ended up bearing the cost. CBP accepts CAPE declarations only from the IOR or from the licensed broker that filed the entries for it, and attorneys cannot file.

In ecommerce, the IOR is often not the brand. Find your situation:

On couriers: CBS News reported the UPS, FedEx and DHL refund pledges in April. All three said they would claim on shipments where they were IOR and pass refunds back to whoever paid. UPS CEO Carol Tomé put the pool at roughly $5 billion, according to Fortune's coverage of the carrier pledges. The carriers can only pay you after Treasury pays them, so expect this money to arrive last.

On DDP and dropship: BDO's IEEPA refund FAQ notes that other parties in the supply chain can negotiate reimbursement with the IOR. That goes better if you can show the duty built into your unit price. If your import paperwork is thin, start with our guide to customs documentation, HS codes and duties.

The tariff refund claim checklist

If you are the IOR, work through these in order. Steps 1 and 2 cause most of the stalls.

1. Get ACE Portal access. A single importer applies through CBP's Importer Account Application. Companies managing several importer numbers use the ACE Portal Account Application web form. If a former employee owned the account, the account owner can reactivate users.
2. Enroll in ACH refunds. CBP pays refunds only by ACH, and your refund bank details are stored separately from the account you use to pay CBP. A non-resident IOR that can't receive ACH needs a CBP Form 4811 designee in place before filing.
3. Export your entry list. Run the ES-003 Entry Summary Line Tariff Details report in ACE and filter for IEEPA Chapter 99 lines. That gives you the eligible population and avoids the "no Chapter 99 line" rejection.
4. Agree with your broker who files. Either of you can file, but not both. Duplicates are one of the three main rejection causes.
5. Sort entries by liquidation date. Unliquidated entries, or entries liquidated within the last 80 days, go into CAPE now. Older entries go to your broker or trade counsel (next section).
6. Build the CSV exactly to the ACE template. Keep each declaration at or under 9,999 entries.
7. Track payment. ES-022 links accepted declarations to entries and refund numbers. REV-603 and REV-615 show pending and paid CAPE refunds. Reconcile these against your bank deposits.

Phase 3 on October 6, and what to do about older entries

CBP's declaration says Phase 3 "covers finally liquidated entries filed by plaintiffs for which the Court has ordered reliquidation." Plaintiffs that gave CBP a valid IOR number by July 30 can file from October 6.

If you never sued, Phase 3 is not for you. As National Law Review's analysis of Phase 3 and liquidation protests puts it, importers without their own reliquidation order from the Court of International Trade "do not become eligible for Phase 3 merely because the system opens." Their options include an individual lawsuit under 28 U.S.C. 1581(i), which must be filed within two years, possible membership in pending class actions (including Freestyle World), or waiting on the government's appeal of the broader refund order.

Two deadlines are worth checking now with your broker:

• Protests. CBP's protest guidance gives you 180 days from liquidation to protest a CBP decision. A protest is a formal written challenge asking CBP to change its duty calculation. For entries liquidated in the spring, that window may be closing.
• Litigation clocks. When a 1581(i) claim "first accrues" depends on the theory of the claim. Ask counsel.

What the tariff refund does to landed cost per SKU

Don't treat the refund as one lump of cash. It belongs to specific entries. Each entry maps to purchase orders (POs) and to SKUs, the individual products you track, such as a blue case for one phone model.

The hypothetical below uses a few cost terms. FOB is the price you paid the supplier with the goods loaded at the origin port. Landed cost is everything it took to get one unit onto your shelf. COGS (cost of goods sold) is what the products you sold cost you. In plain English: the IEEPA duty was $1.60 of each unit's cost, getting it back lifts the margin on every unit, and most of those units are already sold.

Example: one entry, one SKU (hypothetical numbers)

Units imported ................. 2,000
Customs value (FOB $8.00) ...... $16,000
IEEPA duty on the entry ........ $3,200   (say a 20% IEEPA line)

Landed cost per unit, as booked:
  FOB                             $8.00
  Freight + insurance             $1.20
  Non-IEEPA duties (not refunded) $2.00
  IEEPA duty                      $1.60   <- the refundable part
  Broker/fees                     $0.20
  Total                          $13.00

Landed cost per unit, after refund: $11.40

Per-unit margin at a $29.99 price
  (15% marketplace fee $4.50, fulfillment $5.50):
  Before refund: 29.99 - 4.50 - 5.50 - 13.00 = $6.99  (23.3%)
  After refund:  29.99 - 4.50 - 5.50 - 11.40 = $8.59  (28.6%)

Where the $3,200 goes:
  1,400 units already sold ...... $2,240  -> reduces COGS
    600 units still on hand ..... $960    -> reduces inventory value
  Interest on the refund ........ booked separately, not in COGS

You get the 5.3 points of margin back, but mostly on units you already sold. Only $960 improves the cost of stock you still hold. You can rerun the before and after numbers for your own SKUs in our free profit calculator. For a refresher on building the cost stack, see our landed cost walkthrough for imported goods.

Booking the refund without double counting

When you paid the duty, it was added to the cost of your inventory. The refund has to come out the same way. Agree these steps with your accountant:

• Match each refund to its entry, then to its PO and SKUs. ES-022 gives you the entry-to-refund link. Your PO records supply the rest.
• Split sold units from units on hand. The share for sold units reduces COGS in the period you recognize the refund. The share for units on hand reduces inventory cost, so it flows through as those units sell.
• Keep interest separate. CBP includes interest. It is not a product cost, so don't let it inflate your margin figures.
• Don't book it twice. Ask your accountant whether to record the refund as money owed to you (a receivable) when CAPE accepts it, or wait for the cash. Then make sure the ACH deposit clears that receivable instead of becoming a second gain. When the refund comes as a credit on a courier or supplier invoice, match it to the original duty charge.
• Check pass-through promises. If you promised a wholesale customer a duty adjustment, part of this may be theirs.

If your COGS is still a blended monthly figure, our guide to calculating ecommerce COGS shows how to move to per-SKU cost.

Risk notes: pricing and cash timing

Don't cut prices because of the refund. The refund is about the past. Your next purchase order lands under today's duties, not 2025's. The temporary 10% Section 122 surcharge (a stopgap tariff under a different law) that followed the ruling expired at the end of July 23, and new Section 301 forced-labor duties took effect at 12:01 a.m. ET on July 24. Under USTR's fact sheet on the forced-labor action, the rate is 10% or 12.5% across 60 economies covering 99.4% of US imports. China and Vietnam are in the 12.5% tier, per Holland & Knight's breakdown of the country tiers. If the replacement PO in the example above lands at $12.40 a unit, pricing off the refunded $11.40 gives away margin on every sale. For the full duty timeline, see our 2026 US tariff changes guide for sellers.

Plan cash on CBP's timeline, not the headlines. CBP says valid refunds generally go out 60 to 90 days after acceptance, and money routed through carriers or suppliers comes later. Don't commit refund cash to inventory until it clears. If you're weighing a bigger reorder against stockout risk, run the numbers with our post-tariff stockout cost calculator first.

De minimis hasn't come back. De minimis was the rule that let low-value parcels into the US without duty. The IEEPA refund does not revive it. CBP's interim final rule indefinitely suspending de minimis for mail shipments took effect July 24. If your model still assumes cheap parcel imports, reread our breakdown of de minimis and landed cost.

What to do this week

• Log into ACE and confirm your ACH refund enrollment. If you can't get in, ask your broker to check it under its power of attorney (your written permission for it to act for you with CBP).
• Run the ES-003 report, filter for IEEPA Chapter 99 lines, and list every entry with its liquidation date.
• Email your broker to ask which entries it has already put on a CAPE declaration.
• Write to any DDP supplier, dropshipper or platform that acted as IOR. Ask whether they filed and what they will pass back.
• Flag entries liquidated more than 80 days ago and check protest deadlines with your broker or counsel.
• Map each expected refund to its POs and SKUs, and agree with your accountant how and when you'll book it.
• Cost your next purchase order at current duties before you touch any prices.

If the refund and the new duties leave you repricing dozens of SKUs, Nventory keeps their stock and orders in sync across Shopify, Amazon, Walmart and eBay while you do it. The Free plan includes unlimited orders and doesn't require a card.