Importers who paid IEEPA duties keep asking two things: how much money is at stake, and what they should be doing now. Public records answer much of the first and set the dates for the second.
What Treasury’s books show
The Treasury Department reports customs duties every month in the Monthly Treasury Statement, Table 4. From October 2023 through January 2025, net customs receipts ran between $5.2 billion and $7.3 billion a month, and refunds stayed under $1 billion a month. Fiscal year 2024 brought in $77.0 billion.
The first IEEPA duties applied to Chinese goods entered on or after February 4, 2025, under Executive Order 14195. The 10 percent reciprocal duty followed on April 5, 2025, under Executive Order 14257. Net receipts reached $26.6 billion in June 2025 and peaked at $31.4 billion in October. Fiscal year 2025 brought in $194.9 billion.
On February 20, 2026, the Supreme Court held in Learning Resources, Inc. v. Trump that IEEPA does not authorize the President to impose tariffs. CBP stopped collecting IEEPA duties on goods entered on or after February 24, 2026 (CSMS # 67834313). The same day, a 10 percent surcharge under Section 122 of the Trade Act of 1974 took effect, set by Proclamation 11012 to run through July 24, 2026. Gross collections fell from $29.5 billion in January 2026 to between $21.9 billion and $24.8 billion a month from March through August.
The larger change was on the refund line. Customs refunds were $22.0 billion in May 2026, $49.2 billion in June, $33.4 billion in July and $10.5 billion in August. From May through July refunds exceeded collections, and net customs receipts went below zero.
Net customs duty receipts, by month
Billions of dollars, gross collections minus refunds
- 1Feb 2025: First IEEPA duties take effect (China)
- 2Apr 2025: 10% reciprocal duty takes effect
- 3Feb 2026: Supreme Court rules; collection ends Feb. 24
- 4Apr 2026: CAPE refund filing opens
The monthly figures as a table
| Month | Gross receipts | Refunds | Net receipts |
|---|---|---|---|
| Oct 2023 | $7.31 | $0.41 | $6.90 |
| Nov 2023 | $6.70 | $0.40 | $6.30 |
| Dec 2023 | $6.39 | $0.65 | $5.74 |
| Jan 2024 | $6.99 | $0.51 | $6.48 |
| Feb 2024 | $6.75 | $0.54 | $6.21 |
| Mar 2024 | $6.64 | $0.58 | $6.06 |
| Apr 2024 | $7.09 | $0.72 | $6.37 |
| May 2024 | $6.16 | $0.94 | $5.22 |
| Jun 2024 | $6.76 | $0.44 | $6.32 |
| Jul 2024 | $7.63 | $0.49 | $7.13 |
| Aug 2024 | $7.62 | $0.57 | $7.05 |
| Sep 2024 | $7.73 | $0.48 | $7.25 |
| Oct 2024 | $7.95 | $0.65 | $7.30 |
| Nov 2024 | $7.37 | $0.66 | $6.71 |
| Dec 2024 | $7.39 | $0.57 | $6.81 |
| Jan 2025 | $7.88 | $0.54 | $7.34 |
| Feb 2025 | $7.68 | $0.43 | $7.25 |
| Mar 2025 | $8.75 | $0.58 | $8.17 |
| Apr 2025 | $16.30 | $0.67 | $15.63 |
| May 2025 | $22.82 | $0.65 | $22.17 |
| Jun 2025 | $27.15 | $0.52 | $26.63 |
| Jul 2025 | $28.44 | $0.77 | $27.67 |
| Aug 2025 | $30.13 | $0.63 | $29.50 |
| Sep 2025 | $30.49 | $0.82 | $29.67 |
| Oct 2025 | $33.09 | $1.74 | $31.35 |
| Nov 2025 | $31.73 | $0.98 | $30.76 |
| Dec 2025 | $29.33 | $1.44 | $27.89 |
| Jan 2026 | $29.55 | $1.80 | $27.74 |
| Feb 2026 | $27.17 | $0.58 | $26.59 |
| Mar 2026 | $24.02 | $1.86 | $22.15 |
| Apr 2026 | $23.88 | $1.75 | $22.12 |
| May 2026 | $21.93 | $21.97 | −$0.04 |
| Jun 2026 | $23.63 | $49.18 | −$25.56 |
| Jul 2026 | $24.83 | $33.38 | −$8.55 |
| Aug 2026 | $23.38 | $10.54 | $12.84 |
Treasury’s line lumps together ordinary duty, Section 232 and 301 duties, the Section 122 surcharge and IEEPA duties. It does not say how much of the 2025 increase, or of the 2026 refunds, was IEEPA, and the gap between two months is not an IEEPA figure. For that, the source is CBP.
The IEEPA figures CBP has given the court
CBP has given its own numbers to the Court of International Trade in sworn declarations.
- As of March 4, 2026, more than 330,000 importers had paid or deposited about $166 billion in IEEPA duties on more than 53 million entries (declaration of Brandon Lord, March 6, 2026, ¶ 12).
- As of October 2, 2026, about $136.6 billion in potential and certified refunds had been accepted for processing in CAPE, CBP’s refund system, and about $126 billion in refunds, duties plus interest, had been certified and sent to Treasury for payment (Lord declaration, October 6, 2026, ¶ 5).
- On the same date, 20,362 refunds worth about $1.1 billion were on hold because the importer had not given CBP its bank details, and 6.2 million entries submitted on CAPE declarations had failed CBP’s entry-level checks (¶¶ 4, 6).
In an October 8 opinion, the court estimated that if CAPE stopped working that day, about $30 billion in IEEPA duties would remain on deposit at Treasury, and said it believes the importers who have not used CAPE are “overwhelmingly small importers.” CBP’s later declarations do not update the $166 billion total, so a precise figure for all IEEPA duties collected, and the interest owed on them, is not public.
For your own company, the figure that matters is in ACE. CBP’s ES-003 report, run with the IEEPA tariff indicator, lists every entry line on which IEEPA duties were assessed (CBP IEEPA refund page, updated September 30, 2026).
Sort your entries by liquidation date
Liquidation status decides which route is open, so pull the liquidation date for every IEEPA entry.
Not liquidated, or liquidated within the last 80 days. These go on a CAPE declaration in the ACE Portal, and CBP says they need no lawsuit. The 80-day cutoff leaves CBP time to reliquidate within the 90 days that 19 U.S.C. § 1501 allows. ACE liquidates formal entries 314 days after entry, in a weekly Friday run (March 6 declaration, ¶¶ 2, 13), so IEEPA entries made through February 23, 2026 will keep liquidating into early January 2027 unless liquidation is extended. Each one drops out of CAPE’s reach 80 days after it liquidates. Entries flagged for reconciliation qualify until the reconciliation is filed. Filed reconciliations, drawback claims and protested entries are on the list CBP says it is evaluating for later phases.
Liquidated more than 80 days ago. CAPE does not take these from importers who have not sued. Since October 6, it takes them from plaintiffs whose cases carry the court’s reliquidation order and who gave CBP an importer of record number by July 30, 2026 (October 6 declaration, ¶ 8). Plaintiffs who sent the number later are waiting for CBP’s instructions. The court’s order has been entered in more than 4,000 individual cases, which involved about 7,000 plaintiffs as of October 7.
Protested. A protest under 19 U.S.C. § 1514, filed within 180 days of liquidation, keeps the liquidation from becoming final. CBP still lists entries under an open protest among those CAPE does not yet process, though, so a protest is not a route for an entry that CAPE can still take.
The class action and the two-year question
On October 8 the court certified a class in Freestyle World, Inc. v. United States, Court No. 26-01088 (Slip Op. 26-123). The class is every importer of record that paid duties under the challenged IEEPA orders, the trafficking and reciprocal tariffs, between February 1, 2025 and February 19, 2026, except companies that filed their own suit to recover them. It is a Rule 23(b)(2) class, so membership is “mandatory and fixed.” No one opts in or out. The class asks for an order directing liquidation or reliquidation of its members’ entries without IEEPA duties, which would reach finally liquidated entries. That order has not been entered, and the government opposed certifying the class. The parties’ proposed schedule is due October 22.
Separately, the government’s appeal of the court’s earlier orders reaching importers who never sued is pending at the Federal Circuit (No. 26-1895); the importers filed their brief October 5. In its opening brief, the government said importers who have not sued “are free to do so within the statute of limitations.”
That statute is 28 U.S.C. § 2636(i): two years after the claim “first accrues.” When an IEEPA refund claim accrues has not been settled, and the October 8 opinion does not address whether class membership stops the clock. The cautious reading runs it from the date the duties were paid. On that reading, claims on the earliest IEEPA entries, from February 2025, begin to run out in February 2027.
Filing your own case takes you out of the class. Staying in leaves your finally liquidated entries on a remedy the court has not yet ordered and the government opposes. Which risk is larger depends on how many dollars sit on entries that liquidated more than 80 days ago.
Check the money when it arrives
- Refunds go only by ACH to bank details in the ACE Portal, under CBP’s electronic refunds rule in effect since February 6, 2026. Without them, CBP holds the refund, and it pays only the importer of record or the party named on CBP Form 4811.
- CBP says valid refunds generally issue 60 to 90 days after a CAPE declaration is accepted, and that most reach the bank account 3 to 5 weeks after liquidation or reliquidation.
- The refund comes out of a recalculation of the whole entry. CAPE removes the IEEPA Chapter 99 lines and recalculates; other duties still apply, the result can be a bill, and CBP can apply a refund to other debts owed to it. Where a single 15 percent rate was reported under the EU, Japan, Korea or Switzerland framework agreements, only the IEEPA portion comes back.
- Interest under 19 U.S.C. § 1505(c) runs from deposit to liquidation or reliquidation and is folded into the refund. ACE report ES-022 shows principal and interest separately.
- If the amount looks wrong, the court’s October 8 order says to contact CBP through its Centers of Excellence and Expertise.
CBP’s next progress report to the court is due October 26. It will not pause the 80-day count on an entry that liquidates this Friday.