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Insights · IEEPA refunds and CAPE

IEEPA refunds by the numbers, and what to do about yours

Draft. This article is awaiting review by the firm's attorneys before publication.

Prepared by an AI agent. Claude Opus 5.5 (Anthropic) researched, wrote and charted this article from a single prompt. Read the prompt.

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

October 2023: $6.90 billion net (collected $7.31 billion, refunded $0.41 billion) November 2023: $6.30 billion net (collected $6.70 billion, refunded $0.40 billion) December 2023: $5.74 billion net (collected $6.39 billion, refunded $0.65 billion) January 2024: $6.48 billion net (collected $6.99 billion, refunded $0.51 billion) February 2024: $6.21 billion net (collected $6.75 billion, refunded $0.54 billion) March 2024: $6.06 billion net (collected $6.64 billion, refunded $0.58 billion) April 2024: $6.37 billion net (collected $7.09 billion, refunded $0.72 billion) May 2024: $5.22 billion net (collected $6.16 billion, refunded $0.94 billion) June 2024: $6.32 billion net (collected $6.76 billion, refunded $0.44 billion) July 2024: $7.13 billion net (collected $7.63 billion, refunded $0.49 billion) August 2024: $7.05 billion net (collected $7.62 billion, refunded $0.57 billion) September 2024: $7.25 billion net (collected $7.73 billion, refunded $0.48 billion) October 2024: $7.30 billion net (collected $7.95 billion, refunded $0.65 billion) November 2024: $6.71 billion net (collected $7.37 billion, refunded $0.66 billion) December 2024: $6.81 billion net (collected $7.39 billion, refunded $0.57 billion) January 2025: $7.34 billion net (collected $7.88 billion, refunded $0.54 billion) February 2025: $7.25 billion net (collected $7.68 billion, refunded $0.43 billion) March 2025: $8.17 billion net (collected $8.75 billion, refunded $0.58 billion) April 2025: $15.63 billion net (collected $16.30 billion, refunded $0.67 billion) May 2025: $22.17 billion net (collected $22.82 billion, refunded $0.65 billion) June 2025: $26.63 billion net (collected $27.15 billion, refunded $0.52 billion) July 2025: $27.67 billion net (collected $28.44 billion, refunded $0.77 billion) August 2025: $29.50 billion net (collected $30.13 billion, refunded $0.63 billion) September 2025: $29.67 billion net (collected $30.49 billion, refunded $0.82 billion) October 2025: $31.35 billion net (collected $33.09 billion, refunded $1.74 billion) November 2025: $30.76 billion net (collected $31.73 billion, refunded $0.98 billion) December 2025: $27.89 billion net (collected $29.33 billion, refunded $1.44 billion) January 2026: $27.74 billion net (collected $29.55 billion, refunded $1.80 billion) February 2026: $26.59 billion net (collected $27.17 billion, refunded $0.58 billion) March 2026: $22.15 billion net (collected $24.02 billion, refunded $1.86 billion) April 2026: $22.12 billion net (collected $23.88 billion, refunded $1.75 billion) May 2026: −$0.04 billion net (collected $21.93 billion, refunded $21.97 billion) June 2026: −$25.56 billion net (collected $23.63 billion, refunded $49.18 billion) July 2026: −$8.55 billion net (collected $24.83 billion, refunded $33.38 billion) August 2026: $12.84 billion net (collected $23.38 billion, refunded $10.54 billion)
  1. 1Feb 2025: First IEEPA duties take effect (China)
  2. 2Apr 2025: 10% reciprocal duty takes effect
  3. 3Feb 2026: Supreme Court rules; collection ends Feb. 24
  4. 4Apr 2026: CAPE refund filing opens
Source: U.S. Treasury, Monthly Treasury Statement, Table 4, line “Customs Duties,” via the Fiscal Data API. Data through August 2026. Treasury does not split the line by tariff program.
The monthly figures as a table
Customs duties, October 2023 to August 2026, billions of dollars
MonthGross receiptsRefundsNet 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.

How this article was made

An AI agent, Claude Opus 5.5 (Anthropic), prepared this article on October 13, 2026 in about 22 minutes. The prompt below is the only instruction it received. Working from it, the agent read the firm's earlier articles, found and checked the sources, pulled the data, wrote the code that draws the chart, and drafted the text. We publish the prompt so readers can see exactly what the agent was asked to do.

A second automated pass then checked every figure against the Treasury API and every citation against the document it cites. It found one rounding error, January 2026 gross collections given as $29.6 billion instead of $29.5 billion, and corrected it. Nothing else in the text was changed.

The prompt, word for word
You are writing a new article for the Insights section of customscourt.com, the website of Liang + Mooney, PLLC, a customs and international trade law firm in Tallahassee, Florida. The site is an Astro project in the current working directory. Read README.md, DESIGN.md and PRODUCT.md first. Then read the firm's recent articles in src/content/insights/ on IEEPA tariffs, refunds, CAPE and Section 122, so you know what the firm has already published and do not repeat it.

## The article

Importers keep asking two things: how much money is at stake in the IEEPA tariff refunds, and what they should be doing about it now. Answer both, starting from public numbers.

The U.S. Treasury reports customs duty receipts every month in the Monthly Treasury Statement, Table 4, which is available through the Fiscal Data API at api.fiscaldata.treasury.gov. Pull the monthly customs duty figures from October 2023 through the latest month published. Build the article around what they show: the baseline before 2025, the climb as the IEEPA tariffs took effect, and what happened after the Supreme Court's IEEPA decision. Then turn practical. Explain what an importer who paid IEEPA duties should check and do now, with the deadlines that apply.

## Facts

- Every date, statute, case, CBP message, dollar figure and deadline must come from a primary source you actually opened: a court opinion or docket, the Federal Register, a CBP CSMS message or cbp.gov page, a Treasury dataset, or the statute itself. Link those sources in the article text.
- Total customs receipts are not the same as IEEPA collections, because the totals also include Section 232, Section 301 and ordinary duties. Do not present a difference between months as an IEEPA refund estimate unless a primary source supports that reading. If CBP, Treasury or a court has published an IEEPA-specific figure, use it and cite it. If not, say that the precise figure is not public.
- Where something is unsettled, or you could not confirm it, say so plainly instead of guessing. Do not describe any rate, rule, system or deadline as current unless a source dated within the last 60 days supports it.
- Do not promise outcomes and do not quote fees.

## The chart

Include one chart of the monthly customs duty receipts, with the key events marked: when the IEEPA tariffs took effect, the Supreme Court decision, and anything else your sources support.

- Generate it with code, not by hand. Save the raw API response in data/agentic/, write scripts/charts/<name>.mjs to turn it into an inline SVG figure, and paste the generated HTML into the article. Someone should be able to re-run the script next month and get an updated chart.
- Use an inline SVG inside a <figure>, with a <figcaption> that names the source and the month the data runs through. Below it, add a <details> element that holds the same numbers as an HTML table.
- Give each bar or point an SVG <title> with the month and the amount, so the browser shows a tooltip on hover without any JavaScript.
- Style it with classes and the site's existing color tokens, in a short, clearly labeled chart section that you add to src/styles/global.css. It has one series, so no legend box. Keep gridlines recessive, show values in billions of dollars, and make sure it reads at 360 pixels wide.
- Astro renders raw HTML inside markdown, but a blank line inside an HTML block breaks it. The generated figure must contain no blank lines.
- If a dataviz skill is available to you, load it and follow it.

## Voice

Write for an importer's CFO or logistics manager, not for lawyers. Plain, specific, practitioner tone, 900 to 1,400 words, with ## section headings. House style: no em dashes; no "not just X, but Y" constructions; none of these words: transformative, leverage, synergy, journey, unlock, empower, cutting-edge, robust, delve, navigate, embrace, landscape. No closing summary paragraph and no question to the reader at the end. Land the last point and stop.

## File and finish

Save the article as src/content/insights/<slug>.md with this frontmatter: title; date: 2026-10-13; author: "Liang + Mooney, PLLC"; authorSlug: firm; lang: en; topics chosen from src/data/topics.ts; excerpt of one or two sentences; status: review; and

```
agent:
  prompt: ieepa-refunds-by-the-numbers
  model: "Claude Opus 5.5 (Anthropic)"
  prepared: 2026-10-13
```

The site adds the AI disclosure and publishes this prompt on the page, so do not write a disclosure yourself. Do not edit any site files other than the article, the data file, the chart script and the chart styles, and do not commit. Run npm run build and fix anything that breaks. To look at the page, run npx astro preview --port 4330 and leave the Docker preview on port 8087 alone. Finish by reporting the slug, every source you used, and anything you could not verify.

This article is general information, not legal advice, and reading it does not create an attorney-client relationship. The law described here changes, sometimes weekly. For advice about your own entries, notices or deadlines, contact the firm.

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