IEEPA Refunds by the Numbers: What to Check Before Oct. 6

If you're an importer who paid IEEPA tariffs sometime in the last two years, mark your calendar: October 6 is when the next wave of refund money starts moving. That's the launch date for Phase 3 of CBP's refund processing system — and depending on where your entries sit in the queue, it could be the difference between a check landing this quarter or waiting for a phase that hasn't been announced yet.

Here's what's actually happening, and what to do about it before the switch flips.

This isn't abstract policy trivia. Since the Supreme Court struck down the IEEPA tariffs in February, CBP has accepted $134.7 billion in potential and certified refund claims and pushed $122 billion of that to Treasury for disbursement, as of CBP's September 11 figures (GHY International). That's real cash working its way back to the importers who fronted it. But the system moving that money is being rolled out in stages, and which stage covers your entries determines your timeline.

For a small-to-mid-sized brand that's been quietly eating IEEPA duty costs for a year and a half, this is the difference between a refund arriving on a predictable schedule versus sitting in limbo behind entries that are more procedurally complicated.

Quick recap for anyone who tuned out during the legal back-and-forth: on February 20, the Supreme Court held in Learning Resources that the International Emergency Economic Powers Act did not authorize the administration's tariffs. The government didn't simply refund everyone and move on. It pivoted to Section 122 tariffs (a 10% global rate) as a stopgap, which expired July 24, and then rolled out new Section 301 tariffs of 10–12.5% on imports from roughly 60 economies, with some product exemptions. The net effect: the average effective U.S. tariff rate now sits around 6.7%, up from 2.3% in January 2025 (Penn Wharton Budget Model). So "the IEEPA tariffs are gone" doesn't mean duty costs went back to normal. The legal basis changed, and a new tariff structure took its place.

Separately from that policy pivot, CBP still owes refunds on everything that was actually paid under the invalidated IEEPA tariffs — and that's what the CAPE system (Consolidated Administration and Processing of Entries, built inside ACE) exists to process.

CBP didn't attempt to process every affected entry at once — the volume was too large and too varied. Instead, CAPE has rolled out in phases, each covering a different slice of the roughly $135 billion in entries at stake:

If you missed the July 30 cutoff, Phase 3 won't apply to your entries as announced, though CBP has said it will provide additional instructions for plaintiffs who submitted their IOR numbers late (Supply Chain Dive).

Entries involving antidumping/countervailing duties, suspended or extended entries, open protests, and existing drawback claims are still excluded across all three phases — those stay in their own, slower lanes.

Here's the part worth taking seriously even if you've already been approved for a refund: as of CBP's September figures, 20,184 refunds totaling $1.3 billion were sitting untransmitted — not because they were denied, but because the ACH banking information on file was missing or incomplete. Being eligible and being paid are two different things. If your company enrolled for electronic refunds any time ago and hasn't double-checked that enrollment recently, it's worth five minutes to confirm.

Questions specific to your entries go to CBP at [email protected], or the ACE Account Service Desk at 866-530-4172.

Phase 3's plaintiff-only, deadline-gated design suggests CBP is threading the needle between moving fast and staying inside what the courts have actually ordered — which means a Phase 4 covering the remaining excluded categories (reconciliation nuances, currently-protested entries) is a reasonable bet, just not a scheduled one yet. Meanwhile, the tariff landscape underneath all this keeps shifting: Canada implemented retaliatory tariffs on September 8 after trade talks stalled, another live front that has nothing to do with IEEPA but everything to do with what your landed costs look like next quarter.

We'll keep tracking both threads.

Related on Trade Talk: CAPE Phase 3: Who Qualifies, What to Expect, and Key Dates · Can You Claim Drawback on an IEEPA Refund Entry?

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