IEEPA Refunds: Verify You Got the Full Amount

$90 billion accepted is not $90 billion paid

The Supreme Court struck the IEEPA tariffs on February 20, 2026, in Learning Resources v. Trump; roughly 330,000 importers had paid or deposited an estimated $166 billion across more than 53 million entries. CBP's answer is CAPE, the Consolidated Administration and Processing of Entries tool inside the ACE portal, live since April 20, 2026.

Per CBP's June 10, 2026 court declaration, roughly $90 billion in claims had been accepted, but only about $23 billion had been approved and sent to Treasury for payment. Accepted is not disbursed: CBP approves, Treasury pays. A refund effort that stops at the accepted declaration has verified nothing about what arrived.

The method mirrors the line-by-line overpayment check, run in the refund direction; this article is part of The Manufacturer's Guide to Checking Your Tariff Bill.

Step 1: find every IEEPA line, both code ranges

IEEPA duties appear as Chapter 99 lines on the CBP Form 7501, under two ranges, not one: 9903.01 carries the trafficking and border programs (Canada, Mexico, PRC synthetic-opioid, plus the Venezuela, Brazil, and India measures); 9903.02 carries the reciprocal, trade-deficit tariffs across more than 60 countries. A filter built on 9903.01 alone undercounts the entitlement. Filter for both ranges, then refine by country at the eight-digit level.

Two documents build the baseline: your entry summaries, entry by entry, and the Entry Summary Detail Report, ES-003, from your ACE account. ES-003 exports to Excel, and it is the report trade advisories point to for building the entitled-amount list across every entry at once.

Step 2: build the entitled amount, duty plus interest

The entitled amount per entry is the IEEPA duty on those Chapter 99 lines, plus statutory interest: under 19 CFR 24.36 it accrues from the date the duties were deposited to the date of liquidation or reliquidation, and CAPE works by reliquidating entries without the IEEPA duties, so interest applies. The practical test: a deposit that equals raw principal exactly, with zero interest, deserves a second look.

Step 3: know how the money arrives, then run the tie-out

Nothing in any live phase is automatic. The importer of record or its broker files a CAPE Declaration: a CSV, on CBP's template, of up to 9,999 entry numbers, uploaded through the CAPE tab in ACE. An entry you never list never gets refunded. That one sentence is the most basic shortfall cause on the list.

Payment is ACH only and consolidated: refunds group by importer of record, or the party designated on CBP Form 4811, and by liquidation date, issued as one payment, generally within 60 to 90 days of acceptance.

The tie-out is three columns: entitled per entry from the ES-003 baseline; entry numbers actually listed on accepted declarations; deposits received, allocated back to their entry groups. Every entry ends in one of four states: paid in full with interest, paid short, accepted but not yet paid, or never filed. The last two are where the money hides.

Eight verified ways a refund comes up short

• Missed entries. CAPE refunds only the entry numbers listed on an accepted declaration. Anything left off the CSV is not in the queue.
• Excluded categories. Reconciliation-flagged, AD/CVD without Commerce liquidation instructions, drawback, open-protest, USMCA duty-deferral, temporary importation bond, Chapter 98, and non-ACE entries were all outside Phase 1. Some are now Phase 2 eligible; none announce themselves.
• Finally liquidated entries. Not payable in Phases 1 or 2 past 80 days from liquidation; for importers who never sued, contested on appeal.
• Missing or wrong IEEPA lines on the original entry. The refund math inherits the 7501's errors, or the entry draws heightened review.
• ACH never set up. FreightWaves reported roughly $46 billion stalled awaiting ACH authorization in May 2026; without ACH enrollment in ACE, the money sits.
• Treasury offsets. Refunds can be offset against debts owed to the U.S. government, with no explanation attached.
• Opaque partial rejections. CBP does not tell filers which line of a submitted file failed. The rejection classes and fixes are in the CAPE rejection guide.
• The refund landed at the broker. If the broker is the Form 4811 notify party, the deposit goes there; only a broker-statement reconciliation surfaces it.

Each has a next move: file or amend a declaration for anything eligible and unlisted; take finally liquidated entries with no CIT case to counsel, per the appeal below; run short or broker-landed deposits through broker statements and an offset check. The filing mechanics live in the refund pathways guide: it covers how to file, this article covers whether what arrived is complete.

The phase clock, and whether you must act

The 80-day cutoff exists because CBP's voluntary-reliquidation authority under 19 U.S.C. 1501 runs 90 days from liquidation. Phase 2 adds an estimated 2.8 million entries and roughly $28.7 billion; entries whose reconciliation entry is already on file wait for a future phase. Liquidation dates vary entry by entry, so verify eligibility against your own entries with your broker.

The appeal: the honest caveat on finally liquidated entries

The Court of International Trade ordered the government to refund all IEEPA payments to all importers of record, finally liquidated or not. DOJ appealed to the Federal Circuit in early June 2026 (notices filed June 2 and 3), arguing that finally liquidated entries cannot be reliquidated without an importer-specific court order and that the universal injunction exceeds the CIT's authority. Roughly $30 billion is contested.

Who this touches: entries liquidated more than 80 days before a CAPE submission, with no CIT action of your own. Roughly 4,000 plaintiff importers have filed, and under the government's stated Phase 3 position, theirs get processed. For everyone else the protective step is a CIT complaint, a conversation for counsel. That is not urgency theater; it is what a contested appeal does to a refund that would otherwise be arithmetic.

One worked reconciliation

An importer reconciles one consolidated deposit in July 2026. The ES-003 baseline shows 14 entries in one importer-of-record and liquidation-date group, with $168,200 of IEEPA principal; one ACH deposit arrives: $161,540.

The naive read says the refund is short $6,660. The declaration status tells the real story: entry 14, carrying $12,500 of principal, was dropped as reconciliation-flagged, a Phase 1 exclusion. The 13 accepted entries carried $155,700, so the deposit is that principal plus $5,840 of interest, and the interest masked nearly half of the real gap. A missing entry inside a consolidated deposit looks like a slightly small number.

The fix is mechanical: the dropped entry has no type-09 entry on file, so it became Phase 2 eligible on June 29; file or amend a declaration listing it. Without the per-entry baseline, this $12,500 never surfaces.

Hand-check a sample, or upload the entry history

Hand-checking is where to start: pick your ten highest-IEEPA entries, pull both Chapter 99 ranges off each 7501, total the principal, and run the four-state tie-out against declarations and deposits. That is an afternoon, and it settles whether your refunds have a completeness problem at all.

It stops scaling where the duty check did: both code ranges across every line of every entry, interest margins per deposit, deposit allocation across a year of entries. What we can verify first-party: in a recent run, Kynthar's duty engine priced $2.32 million of duty across 532 entry lines and reconciled the total to the dollar. Refund verification is the same reconciliation, run in the refund direction, and the tariff check builds the per-entry IEEPA baseline from the entries you upload.