How $100 Billion in Struck-Down IEEPA Tariffs Is Reaching Importers

The Trump administration has refunded roughly $100 billion of the tariffs collected under the International Emergency Economic Powers Act before the Supreme Court struck down that authority in February — about three-fifths of the approximately $166 billion importers paid under the program.

The figure was disclosed in a declaration filed with the U.S. Court of International Trade by Brandon Lord, executive director of the Trade Programs Directorate at U.S. Customs and Border Protection. Lord said the refunds, covering duties plus interest, have been certified and sent to the Treasury Department for disbursement, and that CBP's accounting system confirms Treasury is paying them out on a regular basis.

The payouts are being processed through a dedicated CBP portal, the Consolidated Administration and Processing of Entries (CAPE), which went live in late April 2026. As of July 31, the portal had received 252,496 refund declarations, and 178,213 passed initial file validation, Lord said. Those accepted filings cover 25.1 million import entries, of which 17.69 million have been liquidated or reliquidated without IEEPA duties. Roughly $128.68 billion in claims — including both potential and certified refunds — are in the processing pipeline.

The pace of disbursement has picked up sharply: Treasury paid out $49.2 billion in customs refunds in June, more than double the roughly $22 billion paid in May, for a combined $71 billion across the two months. The remaining task is still large, however — the affected universe stretches to more than 330,000 importers and upward of 53 million entries, and the disclosure came amid litigation over access to the refund system.

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The Refund Backlog, the Stuck $1.6 Billion and the Fight Over Trade Authority

The refund arithmetic: $100 billion out, $128.7 billion in the pipeline

The gap between what has been refunded and what is in the system is the real story. The $100 billion already certified represents only about 60 percent of the $166 billion collected, and the $128.68 billion in claims at various stages of processing suggests the final bill could approach the total intake once interest is factored in. With 17.69 million of 25.1 million covered entries already liquidated without IEEPA duties, CBP is roughly 70 percent through the entries attached to accepted declarations — but the 330,000-importer, 53-million-entry universe is far larger than what the portal has processed so far. On the numbers disclosed, full resolution is a matter of quarters, not weeks.

The $1.6 billion stuck on missing bank details

Not every certified refund reaches its recipient. Lord disclosed that 19,726 refunds totaling about $1.6 billion have not been transmitted to Treasury because importers have not supplied the required bank account information. That is a small slice of the total, but it is a telling one: it shows the program's friction is administrative as much as financial, and it lends texture to the claim at the center of the Freestyle World litigation — that smaller companies in particular cannot effectively work the CAPE system.

Freestyle World and the access question

Freestyle World, a California importer, is seeking class-action certification on behalf of smaller companies that paid IEEPA duties and argue they cannot practically access the CAPE portal. The government counters that the class-action request is untimely and invalid. The stakes are concrete: if certification succeeds, the case becomes a mechanism for hundreds of thousands of importers to challenge refund access; if it fails, smaller firms are left to navigate the portal on their own. This is a fight about process, but the money attached to it runs to tens of billions of dollars still in the pipeline.

The legal ground is still shifting

The refunds are a consequence of the Supreme Court's February decision striking down the IEEPA authority the tariffs rested on. What the story notes but does not resolve: the administration is simultaneously pursuing alternative legal avenues to restore the tariff structure, an effort that has already drawn its own wave of litigation. For importers, that means the refund process is running alongside a policy drive to re-impose broadly similar duties under different authority — so today's refund could precede tomorrow's new levy on the same goods. Any planning around refunded cash should account for that legal uncertainty.

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What Importers Awaiting IEEPA Refunds Should Do Now

For importers still awaiting IEEPA refunds:

  • Make sure CBP has your bank account information on file: the government is holding 19,726 certified refunds worth about $1.6 billion solely because filers have not supplied account details, and no money moves to Treasury until that is fixed.
  • Track your claims through the CAPE portal: the system has processed 252,496 declarations, 178,213 of which have passed validation, and 17.69 million import entries have already been liquidated without IEEPA duties.
  • Smaller importers that cannot access or navigate CAPE should watch the Freestyle World class-action case at the U.S. Court of International Trade; its outcome determines whether unresolved claims get an alternative channel.
  • Expect the pace of payout to keep climbing in the near term — Treasury disbursed $49.2 billion in June versus $22 billion in May — but the roughly $28.7 billion difference between cash refunded and claims in the pipeline means backlogged claims will take time.
  • Keep documentation for refunded entries: the administration is pursuing alternative legal authority to restore the tariffs, so decisions about future duties on the same goods are not settled.

Risk & Opportunity Assessment

Commercial RiskMediumRoughly $28.7 billion in claims remain in the pipeline beyond the $100 billion already paid, and $1.6 billion of certified refunds are held for missing bank details, leaving importers' cash tied up for months.
Competitive RiskMediumFreestyle World's class action alleges smaller importers cannot effectively access CAPE, while larger firms with customs resources are getting refunds processed first, potentially skewing who recovers cash fastest.
Regulatory RiskHighThe administration is pursuing alternative legal authority to restore the tariff structure, which could re-impose duties on the same imports and is already generating new litigation.
Reputation RiskMediumA class action over portal access and the slow pace of payouts — 40% of collected duties still unreimbursed — puts CBP's administration of the refund program under judicial and public scrutiny.
Technology DisruptionLowThe new CAPE portal processes 252,496 declarations, but it is an administrative tool; it does not change industry economics or business models.
Commercial OpportunityMediumImporters are recovering working capital — $100 billion including interest already certified — and import-dependent businesses regain cost relief if refunds fully clear.