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un-tariff / IEEPA Refund
Updates · Log

IEEPA refund developments, logged as they happen.

Every CBP CSMS release, every executive order touching IEEPA duties, every relevant court decision — summarized here with links to the authoritative sources. No commentary. Just what changed and where to verify it.

  1. CBP

    CBP issues CSMS UPDATE (#68340863) with CAPE Phase 1 implementation details

    CBP released a follow-up CSMS message on April 17 clarifying CAPE Declaration mechanics: per-file 9,999-entry cap, CSV format requirements, and the 60–90 day payment target following acceptance. This builds on the April 10 introduction bulletin (#68315804).

  2. CBP

    CBP publishes IEEPA refund FAQ

    CBP's trade-remedies group posted a public FAQ covering who can file, what counts as an IEEPA entry, how interest is computed, and what happens when an entry stacks with Section 232/301. Hogan Lovells and BDO published companion analyses the same week.

  3. CBP

    CBP confirms CAPE Phase 1 launch for April 20 with Trade Information Notice

    CBP published a formal Trade Information Notice fixing the CAPE Phase 1 go-live for 8:00 AM ET on April 20, 2026. Phase 1 covers unliquidated entries plus entries within the 80-day post-liquidation window. Confirmed by Covington, Thompson Hine, Forvis Mazars, and Cherry Bekaert alerts.

  4. CBP

    CBP introduces CAPE via CSMS #68315804 — first confirmed deployment date

    The original CSMS introduction bulletin set April 20 as the Phase 1 deployment target and described the ACE Portal submission flow: CSV upload of entry numbers, IOR + filer-code attestation, and ACH-based refund disbursement.

  5. Executive

    CBP stops collecting IEEPA duties at midnight ET

    Following the executive order terminating the invalidated tariffs, CBP's Feb 22 CSMS confirmed that IEEPA duties will not be collected for goods entered for consumption on or after 12:00 AM ET on February 24, 2026. The Section 122 replacement regime — a 10% global tariff for up to 150 days — began the same day.

  6. SCOTUS

    SCOTUS decides Learning Resources v. Trump 6-3: IEEPA does not authorize tariffs

    Chief Justice Roberts, joined by Justices Sotomayor, Kagan, Gorsuch, Barrett, and Jackson, held that IEEPA's 'regulate importation' language does not include the power to impose tariffs. The Court vacated and remanded. Justices Thomas, Kavanaugh, and Alito dissented. The ruling affirmed the Federal Circuit's August 2025 decision. Congressional Research Service, Brookings, and Penn Wharton published same-day and next-day analyses.

About these sources

Primary sources are the Supreme Court, CBP (CSMS and Trade Information Notices), the White House, the Federal Register, and the Congressional Research Service. Secondary sources are international trade-law practice groups at top-tier firms (K&L Gates, Sidley Austin, Ropes & Gray, WilmerHale, Covington, Norton Rose Fulbright, Thompson Hine, Hogan Lovells, White & Case, Holland & Knight, Troutman Pepper) and major accounting advisories (BDO, Forvis Mazars, Cherry Bekaert). No links are paid. Inclusion is not endorsement — it is where we verify claims.