CBP has begun refunding $11.4 billion in finally liquidated International Emergency Economic Powers Act (IEEPA) duties, the agency told the Court of International Trade in an Oct. 6 filing — the third phase of a CAPE refund pipeline that now totals roughly $136.6 billion.

The latest phase opened in October after a delay from a targeted end-of-July start. It targets entries that were already finalized before the Supreme Court invalidated IEEPA tariffs in February, a separate bucket from the still-open and unfinalized entries that dominated earlier refund waves.

How big is the third tranche?

As of Oct. 6, U.S. Customs and Border Protection had accepted 477 finally liquidated entry declarations covering 425,517 entries, per the filing. Brandon Lord, executive director of CBP's Trade Programs Directorate, said organizations must apply through the agency's Consolidated Administration and Processing of Entries portal, known as CAPE.

The finally liquidated tranche covers roughly 6.9% of all IEEPA tariffs — the last retrievable bucket from a tariff regime that touched importers across consumer goods, industrial inputs and apparel.

"Another important step in the CAPE process — and one importers involved in the tariff litigation will want to continue to monitor," Kelly Nelson, principal consultant and managing director of KPMG Trade & Customs Services, said on LinkedIn.

Takeaway: $11.4 billion in recovered duty is real working-capital relief, but only for importers whose paperwork cleared the July 30, 2026, cutoff.

Who actually qualifies this round?

Only plaintiffs who submitted a valid importer of record number to CBP by July 30, 2026, can currently collect. Anyone who filed after that date must wait for further instructions; CBP has not published a timeframe for that next cohort.

The cutoff is hard, not curable. Distributors and wholesalers that held off on filing — or whose brokers missed the window — are locked out of this phase. They will get a refund only if and when CBP publishes a separate process, which the agency has not yet committed to.

Takeaway: the deadline already passed; late filers are now in a queue with no published arrival time.

How much of the broader pipeline is already paid out?

As of Oct. 2, CAPE had accepted roughly $136.6 billion in potential and certified refunds for processing. Of that, $126 billion had moved to the Treasury Department for disbursement.

The refund pipeline broke into three visible phases:

• First phase: unprocessed entries (those still in the customs queue when the Supreme Court ruled)
• Second phase: unfinalized entries
• Third phase: finally liquidated entries, the $11.4 billion bucket now open

Each phase carries its own eligibility rules. The finally liquidated phase is the most procedurally contested because those duties were already booked as final revenue before the high court's decision.

Where does the appeal stand?

The Justice Department is fighting the refund order at the Federal Circuit Court of Appeals. Its argument: the Court of International Trade overreached when it ordered universal refunds for finalized entries, and the ruling should be limited to the specific plaintiffs who sued.

CAPE is paying out the finally liquidated tranche regardless of how the Federal Circuit eventually rules, because the CIT order is being executed under the court's authority while the appeal proceeds.

The residual risk for importers: if the Federal Circuit reverses and claws back refunds already disbursed, recipients could face demands for repayment. Customs brokers are advising clients to treat any recovered duty as a contingent liability rather than booked income until the appellate window closes.

Takeaway: the checks are moving, but appellate overhang keeps every refund provisional.

What's the importer playbook now?

Three actions for operations and finance teams sitting on potentially eligible entries:

1. Confirm that an importer of record number was submitted to CBP by July 30, 2026 — missed deadlines are not curable under current CAPE rules.
2. Pull entries from the period the IEEPA tariffs were in effect (primarily 2025, when bulk collections occurred) and run refund eligibility line by line.
3. Track the Federal Circuit docket. Any reversal narrows the universe of paid refunds and changes the contingent-liability math.

CBP has not published a timeline for plaintiffs who filed after the July 30 cutoff, and the Federal Circuit appeal is pending with no oral argument date on the public docket as of mid-October.