On 20 February 2026 the US Supreme Court ruled, by a 6–3 majority, that the International Emergency Economic Powers Act (IEEPA) does not give the President the authority to impose tariffs.¹ US Customs and Border Protection (CBP) stopped collecting the IEEPA duties at 12:00 a.m. Eastern time on 24 February 2026.² The Court itself said nothing about whether, and how, the money should be returned, and the Court of International Trade later ordered refunds for entries that had not yet been liquidated.¹ CBP has since built a refund process of its own, in phases, and it works entry by entry. This article applies to goods imported into the United States.
The short version
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Only importers of record
The importer of record, or the customs broker who filed the entry, can claim. CBP pays the importer of record.³ ⁴
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IEEPA duties only
Refunds cover IEEPA duties collected from February 2025 until 24 February 2026. Section 232 and 301 duties are unaffected.¹ ² ⁷
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Interest included
Refunds include statutory interest and are generally issued within 60 to 90 days of a declaration being accepted.³
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Every entry has its own clock
Entries already finally liquidated generally need a court claim, and protests have a 180-day limit.⁵
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Last updated: October 2026
01 · Timeline
How We Got Here
| 20 Feb 2026 | Supreme Court rules that IEEPA does not authorise tariffs.¹ |
| 24 Feb 2026 | CBP stops collecting IEEPA duties.² |
| 20 Apr 2026 | CAPE opens. Phase 1 covers unliquidated entries and those liquidated within 80 days.³ |
| 29 May 2026 | CBP states it cannot refund finally liquidated entries without a court order.⁵ |
| 2 Jun 2026 | The government appeals the order requiring universal refunds.⁶ |
| 29 Jun 2026 | Phase 2 adds certain entries flagged for reconciliation.⁴ |
| 6 Oct 2026 (planned) | A further phase for finally liquidated entries, initially only for importers with a court reliquidation order.¹⁰ |
02 · Scope
What Is, and Is Not, Covered
Refunds cover IEEPA duties only, which were collected from February 2025 until collection stopped on 24 February 2026.² ⁷ Other tariffs, including those under Section 232 and Section 301, were not affected by the ruling and remain payable.¹ ⁷ Brokerage, operational and service charges paid to a carrier are also not refunded.⁸
Not every shipment in that period will qualify automatically. It depends on the customs entry record and on the phase of the CBP process the entry falls into.³ In Phase 1, CBP excluded, among others, reconciliation entries, drawback entries, USMCA duty deferral entries, entries with open or suspended protests, antidumping and countervailing duty entries in pending status, and entries more than 80 days past liquidation.³
03 · Eligibility
Who Can Claim, and Who Gets Paid
Only the importer of record (the party named on the customs entry) or the customs broker who filed it can submit a claim to CBP.³ ⁴ ¹² CBP pays the refund to the importer of record, by electronic transfer to the bank account set up in its Automated Commercial Environment (ACE), even when a broker or carrier submitted the claim.⁸ ⁹ CBP pays only by electronic transfer, not by cheque or cash.⁸
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If you paid a carrier
Paying an invoice to a carrier does not by itself make you the party CBP refunds. Where the carrier was the importer of record, it receives the money from CBP first, and carriers have said refunds depend on CBP paying them first.¹² Whether and how the money then reaches you depends on the carrier’s role and its own process.
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04 · The process
How the CBP Process Works
Claims are made through CAPE (Consolidated Administration and Processing of Entries), a module in the ACE Portal. The importer or broker uploads a file listing the entry numbers, up to 9,999 per declaration, and the declaration can only be submitted by the importer of record or the broker that filed the entry.³ Refunds include statutory interest, calculated under 19 CFR 24.36.³
For entries that have not yet liquidated, CBP sets them to liquidate 45 days after the declaration is accepted, and refunds are generally issued within 60 to 90 days.³ Entries that are under review, suspended or awaiting liquidation can take longer.⁹ Phase 1 covers entries that are not yet liquidated and those liquidated within the preceding 80 days, which matches CBP’s 90-day voluntary reliquidation window.³ ¹¹
05 · Deadlines
Every Entry Has Its Own Clock
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Don’t wait on older entries
For entries that have already been finally liquidated, CBP stated on 29 May 2026 that it lacks the legal authority to refund them without a court order, which means a separate claim at the US Court of International Trade.⁵ The government also appealed the court order requiring universal refunds in June 2026, so the position for older entries is still being contested.⁶ For an entry liquidated recently, a protest filed with CBP within 180 days of liquidation keeps the option open.⁵
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Law-firm reporting of CBP’s court filing says CBP plans to open a further CAPE phase on 6 October 2026 for finally liquidated entries, but initially only for importers that have sued and obtained a court reliquidation order.¹⁰ That is a plan, not a guarantee. If you have older entries, ask your customs broker or a customs lawyer about each one now, rather than waiting.
06 · Carriers
If FedEx, DHL or UPS Cleared Your Shipment
The route depends on the carrier’s role. Check which of these applies to each entry.
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FedEx
FedEx filed Phase 1 and Phase 2 declarations on behalf of customers where it served as broker, whoever the importer of record was, unless the customer opted out. It began receiving refunds from the government on 11 May 2026 for entries where it was the importer of record or was designated by the importer. Its portal shows whether FedEx has received refunds from CBP, including interest, and lets you submit payment and tax information, such as a signed W-9 or W-8 form and bank details. FedEx states it does not charge a fee for this service. For finally liquidated entries it can file only where it was itself the importer of record.⁷
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DHL Express
Where DHL was the importer of record, it files eligible first-phase entries automatically and returns the refund to the party that originally paid the duties, which DHL says can take another 30 to 90 days after it receives the money. Where you were the importer of record, you can file yourself in CAPE, with the refund paid to your own ACE account, or authorise DHL to file for you using its form, which carries an import documentation fee of USD 2.10 per entry. Confirm your importer-of-record status on CBP Form 7501 and set up an ACH refund account in ACE first.⁸
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UPS
Where UPS was the importer of record, no action is needed and UPS manages the refund with CBP. Where UPS was only the broker, you can prepare and submit your own CAPE filings, with the refund paid to you by electronic transfer, or use UPS’s optional paid filing service. UPS states that refunds are issued to the importer of record listed on the entry, and that CBP does not evaluate private arrangements between parties about passing costs on, so check your shipment with UPS.⁹
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For reference, the shipments GENERAL BYTES sent in the affected period went with FedEx or DHL only. Goods from other suppliers may have travelled with other carriers.
07 · Questions
Common Questions
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Can I claim if I am not the importer of record?
Not directly from CBP. Only importers of record and their brokers can file in CAPE, so businesses and consumers that paid duties through a carrier depend on the carrier to file and pass the refund on.³ ¹²
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Does the refund include interest?
Yes. CBP refunds include statutory interest.³ Part of a refund may therefore be interest, which can be taxable, so it is worth mentioning to your accountant.⁷
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How long will it take?
CBP generally issues valid refunds within 60 to 90 days of a declaration being accepted.³ Carrier routes can add time, for example another 30 to 90 days at DHL where it was the importer of record.⁸
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Is there a deadline?
There is no single date for a whole company. Each entry has its own clock, tied to its liquidation date, so note the liquidation date of every entry in ACE.⁵ ¹¹ ¹⁴
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08 · Next steps
Ready to Claim? Start Here
| 1 | Check who is listed as importer of record on your customs entries, for example on CBP Form 7501 or in your broker’s records. |
| 2 | Collect your entry numbers and the air waybill or tracking numbers for the affected shipments. |
| 3 | Note the liquidation date of each entry in ACE. |
| 4 | Choose your route: your broker or ACE, or your carrier’s refund portal. |
If you are unsure how to claim, contact your customs broker, your carrier or US Customs directly. The official CBP page on IEEPA duty refunds is linked in the sources below.¹³
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Questions about your GENERAL BYTES shipments?
Reach out to our team at sales@generalbytes.com and we will help you find the information you need.
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Sources and references:
1. Steptoe — US Supreme Court strikes down IEEPA tariffs (decision of 20 February 2026, 6–3; Section 232, 301, 122 and 338 authorities unaffected), 2. CBP bulletin — termination of IEEPA duties at 12:00 a.m. Eastern time on 24 February 2026, 3. CBP CSMS #68340863 — CAPE for IEEPA refunds, Phase 1 (20 April 2026) (eligibility and exclusions; who may file; interest; 45-day liquidation and 60–90 day refund timing), 4. CBP bulletin — CAPE deployment of 29 June 2026, 5. Sheppard Mullin — CBP reverses position on universal IEEPA duty refunds (CBP position of 29 May 2026; 180-day protest), 6. Morgan Lewis — tariff refund battle continues: government appeals order (appeal filed 2 June 2026), 7. FedEx — IEEPA tariff refunds & FedEx refund portal FAQ, 8. DHL Express — IEEPA tariff refunds, DHL Express information page & DHL Express refund form, 9. UPS — how to request IEEPA tariff refunds, 10. ALS — CAPE Phase 3 and the litigation requirement (planned 6 October 2026 deployment), 11. Holland & Knight — CAPE has arrived: navigating the next phase of IEEPA duty refunds, 12. CBS News — UPS, FedEx and DHL are seeking tariff refunds: what it means for consumers, 13. CBP — IEEPA duty refunds (official page), 14. Strix — IEEPA refund deadlines per entry
Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, customs, tax, or investment advice. Eligibility, deadlines, phases and fees are set by US Customs and Border Protection, the courts and the carriers, and may change; the refund rules for older entries are still being contested in court. Always confirm the current position with your customs broker, your carrier or CBP before filing. Information current as of October 2026.
