Source: Supply Chain Dive
Date: 17th September 2026 

A new phase of the U.S. tariff refund process will allow certain finally liquidated entries to be considered for reimbursement, giving importers another opportunity to recover duties previously paid under invalidated IEEPA tariffs.

U.S. importers affected by former tariffs imposed under the International Emergency Economic Powers Act (IEEPA) will see another important development in the refund process from October 6, 2026.

U.S. Customs and Border Protection (CBP) is preparing to expand its Consolidated Administration and Processing of Entries (CAPE) system to process certain finally liquidated entries, customs entries for which the liquidation process has already been completed.

According to a recent court filing, businesses that provided CBP with a valid Importer of Record (IOR) number by the end of July will be able to seek refunds for eligible finally liquidated entries through CAPE beginning October 6. Importers seeking refunds for entries submitted after July 30, 2026 will need to wait for further instructions.

The development follows the U.S. Supreme Court’s February decision invalidating tariffs imposed under IEEPA and the subsequent creation of a phased process for returning affected duties to importers.

Refund process expands. Earlier phases of CAPE covered other categories of entries, while the capability to process finally liquidated entries had been delayed.

The latest phase is significant: approximately $11.4 billion, or 6.9% of the affected IEEPA tariffs, relates to this category of entries.

The overall refund process is already substantial. As of September 11, CBP had accepted approximately $134.7 billion in potential and certified refunds for processing, according to the latest court filing cited by Supply Chain Dive.

However, the October expansion should not be interpreted as an automatic refund for every importer with a finally liquidated entry.

Legal proceedings concerning the scope of refunds remain ongoing. The U.S. government has challenged whether refund orders should extend universally to finally liquidated entries belonging to importers that were not parties to the relevant litigation.

What This Means

• Businesses that previously paid affected IEEPA tariffs should identify potentially eligible entries and review their customs records ahead of October 6.
• Particular attention should be given to Importer of Record information, entry and liquidation status, supporting customs documentation and the specific legal eligibility applicable to each refund claim.
• Importers should also avoid treating potential refunds as confirmed recoveries until eligibility has been established.

The expansion of CAPE highlights how rapidly changing trade measures can continue affecting businesses long after duties have initially been paid.

For importers, customs management increasingly involves not only determining the correct duties at the time of entry, but also maintaining accurate historical entry records and monitoring subsequent regulatory and legal developments that may create opportunities for recovery.

With the next phase beginning October 6, businesses with affected U.S. imports should review their entry records early and work with their customs specialists to determine which entries may qualify for the developing refund process.