$85B in Tariff Refunds: Claim Yours Before You Lose It

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At 6:32 this morning, the U.S. Customs and Border Protection refund number jumped from $35 billion to $85 billion in a single court filing, and a lot of ecommerce operators still don’t know they have a claim sitting on the table. This is one of the largest refund processes the federal government has ever attempted, and the part that should make you pay attention is that it’s not automatic. You file, you collect. You don’t file, the money goes back into Treasury and nobody calls you to apologize.

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If you’ve been importing anything since April 2025 (consumer electronics, e-bikes, furniture, apparel, mobility gear, fitness equipment, basically any high-ticket SKU sourced from outside the United States), there is a real chance you’re owed a refund with interest. Here at Ecommerce Paradise we’ve been tracking the IEEPA tariff saga since the Supreme Court ruling in February, and yesterday’s CBP filing changed the math for thousands of small importers and dropshippers who didn’t think they had skin in the game.

I’m going to walk through what CBP actually said, how we got here, why it matters for your store specifically, and the step-by-step you should be running this week to get your refund in the queue before the door starts closing on Phase 1 entries.

When a federal agency starts processing $85 billion in refunds, the address on your LLC filing is the address they will use. Make sure it’s not your home. See how I keep my filings private with Northwest →

What Happened

On Tuesday, May 26, 2026, U.S. Customs and Border Protection told the Court of International Trade in a sworn court filing that it now expects to process approximately $85 billion in potential and certified refunds tied to tariffs the Supreme Court invalidated earlier this year. That’s a sharp jump from the $35 billion figure CBP gave the court just thirteen days earlier, per Supply Chain Dive’s reporting on the filing.

As of May 22, about $20.6 billion in certified refunds with interest have actually been completed through the Consolidated Administration and Processing of Entries portal, which CBP calls CAPE. CAPE went live on April 20, 2026 and lives inside the existing Automated Commercial Environment, the same ACE portal importers and brokers already use for trade documentation. The certified refunds have been transmitted to the Treasury Department for disbursement, but the agency disclosed that 4,185 consolidated refunds were held back because the importer or the company designated to receive refunds on its behalf had not uploaded a U.S. bank account for ACH deposit.

The volume CBP is sitting on

The agency reports that more than 15.85 million entries with tariffs the Supreme Court ruled illegal have been accepted for duty removal through CAPE. More than 8.51 million of those accepted entries have already been liquidated or reliquidated without the invalidated tariffs, which is the technical step that triggers a refund check. About 3.48 million entries through CAPE have failed entry-level validations, and the three primary reasons for failure are entries falling outside CBP’s 90-day reliquidation authority, entries already included in a prior CAPE submission, and entries that never had the special tariff code attached that flagged them as IEEPA duties in the first place.

On the file side, importers and customs brokers had sent 157,402 refund files through CAPE as of May 22, with 108,760 of those passing CBP’s initial checks. That’s a 69% pass rate on first submission. The common causes of file-level rejection, per CBP, are importer or filer mismatches, bad entry numbers, and CSV files that don’t conform to the template ACE publishes. A lot of operators are submitting once, getting rejected, and not coming back, which is leaving real refund money stranded.

What CBP corrected in this filing

One important detail in the May 26 filing: CBP lowered the anticipated refund amount for entries that have been finally liquidated from $35.46 billion to $25.46 billion. The agency clarified that the overstatement was due to an error in its data query, not a problem with CAPE processing itself. The total expected refund pool is still $85 billion when you include Phase 1 unliquidated entries, entries that liquidate within the 80-day window, and the eventual Phase 2 process that will eventually handle finally liquidated entries currently outside the system.

The agency also said it is still developing the capability to process entries that have been finally liquidated, and the Court of International Trade is pushing CBP to deliver that capability soon, per a CBP IEEPA Duty Refunds page covering the process. Tax advisors at RSM US have published a Phase 1 eligibility breakdown that mirrors what CBP itself put in the court record, and a Time Magazine writeup from when CAPE launched gives a useful operator-level summary of who can file and what to expect. Until that’s live, a meaningful share of small importers, especially anyone who paid duties on shipments that liquidated more than 80 days ago, is in a holding pattern.

How We Got Here

The International Emergency Economic Powers Act is a 1977 statute originally designed to give the president broad authority to regulate international economic transactions during declared national emergencies. It was used sparingly for decades, almost always for sanctions and asset freezes targeting specific countries or individuals, never as a mechanism to impose broad import duties on legal commercial trade.

That changed in early 2025 when the Trump administration invoked IEEPA to impose what became known as the universal tariffs, including the 10% global tariff and country-specific add-ons that pushed total effective rates above 50% on some categories. About 330,000 importers ended up paying or depositing an estimated $166 billion across more than 53 million entries, according to CBP and court filings reported by Norton Rose Fulbright in its CBP refund instructions writeup.

The legal challenge moved fast. A coalition of importers, trade associations, and a handful of small businesses challenged the IEEPA tariffs in the U.S. Court of International Trade, arguing the statute was never meant to authorize duties on routine commercial imports. The case made it to the Supreme Court, which ruled in February 2026 that the IEEPA-based tariffs were unlawful. Then in May 2026, the Court of International Trade went further and ruled that the residual 10% global tariff was also illegal, which expanded the refund pool again.

That Supreme Court ruling forced CBP into a position it had never been in before, processing refunds for tens of millions of entries from hundreds of thousands of importers, including a lot of small dropshippers and brand stores who had never directly dealt with CBP’s electronic systems. The agency spent six weeks building CAPE on top of ACE, and the system went live on April 20. Phase 1, the part that’s running now, is limited to certain unliquidated entries and entries that liquidated within 80 days of the CAPE submission date.

Why This Matters for Your Store

Here’s the operator-level math you should be running. If you imported $200,000 worth of inventory in 2025 and paid an average effective IEEPA tariff of 15% on top of standard duties, you paid about $30,000 in IEEPA duties. The refund covers the IEEPA portion plus interest, which means you’re potentially looking at $30,000 plus 8% to 10% per year of interest, depending on how long the money has been sitting with Treasury. That’s not free money exactly because you’ve already deducted it from your books, but it is real cash that lands in your operating account and changes your Q3 P&L significantly.

The size of the check matters less than the timing of when you go after it. The reason 4,185 importers are sitting on stranded refunds, per the same court filing, is that they didn’t put their U.S. bank account information into the ACE portal. That’s a 15-minute fix that’s costing some operators tens of thousands of dollars right now. If your business pays international suppliers, run that USD account through a multi-currency setup like Wise for moving money to suppliers, but keep a clean ACH-capable U.S. business checking account on file with CBP so the refund actually lands.

Who actually qualifies in Phase 1

Only the Importer of Record, or a customs broker the IOR authorizes, can submit a CAPE Declaration. If you’ve been using a freight forwarder who handled all the entry filings under their own importer number, you need to confirm whether they were the IOR or you were. Most high-ticket dropshippers who ship from a U.S. warehouse use the warehouse or 3PL as the IOR, which means the refund flows to them first and they decide whether and how to pass it back. The carriers that have come out publicly on this are FedEx, UPS, and DHL Express, who have all said they will return refunds to the customers whose shipments paid the duties. Smaller 3PLs have not all made that commitment yet.

If you sell anything where you took title to inventory at a port and acted as IOR, you should be filing yourself or paying your customs broker to file. If you sold purely as a marketplace seller and never touched physical inventory, you almost certainly don’t have a direct claim, but your suppliers might, and the refund could flow back through better wholesale prices in the second half of the year.

The accounting trap

The refund is taxable income in the year you receive it, with interest taxed separately. If you already deducted the IEEPA duties as cost of goods sold or operating expenses on your 2025 return, the refund creates a reversal that has to be accounted for cleanly. This is the kind of thing I see operators get wrong because they’re treating it like a windfall instead of a tax event. If you’re not running a real bookkeeping stack, this is the moment to fix that. I use Finaloop on my own stores because it categorizes ecommerce-specific transactions automatically and tags refund income as a reversal of the original deduction. If your accountant is more traditional, QuickBooks with a competent bookkeeper can do the same job, just less automatically.

If reading this is the moment you realize the operational complexity of running a high-ticket store, dealing with import paperwork, registered agent filings, customs brokers, and accounting reversals is more than you signed up for, this is exactly what my turnkey done-for-you service handles end to end. We build the store, set the supplier relationships, run the import structure correctly from day one, and operate the back end so you don’t have to interpret CBP filings yourself.

The second-order effect on supplier pricing

This is the part most operators are not pricing in yet. If your supplier is a U.S.-based brand that imports from China or Vietnam and they’re getting a meaningful IEEPA refund, that refund changes their landed cost retroactively. Some suppliers will keep the entire refund as windfall and quietly improve their margin. Some will share it with retailers through a one-time MAP adjustment or a temporary spiff. The best operators are reaching out to their top three suppliers this week to ask, on paper, whether the supplier is filing for IEEPA refunds and whether retailers will see any of the benefit through pricing. Suppliers who say no get an honest pricing comparison against alternatives. That’s worth a real conversation, not just a passive note in your inbox.

New to high-ticket dropshipping and this all sounds like a different language? Grab my free high-ticket beginner guide and start with the fundamentals →

What To Do This Week

  1. Pull your 2025 import history. Get your full list of CBP entry numbers for shipments where IEEPA tariffs were paid. If you used a customs broker, ask them for an entry summary report covering April 2025 through November 2025. If you self-filed, log into ACE and run a 2025 entry list. You need entry numbers in clean format to populate the CAPE Declaration CSV. Pulling this together yourself usually takes a couple hours; having a broker pull it is faster but costs a fee.
  2. Confirm your ACH banking is set up in ACE. This is the 15-minute fix that’s leaving 4,185 importers stranded right now. Log into the ACE Portal, head to your account profile, and verify your U.S. business checking account is registered for ACH deposits. If you’ve been paying customs duties by check or by broker, your ACH info may have never been added. Use a clean business checking account, not a personal one, and not Wise (Wise is excellent for paying international suppliers, but use a domestic bank for the CBP ACH connection).
  3. Decide on self-file vs. broker-file. If you have a customs broker who already handles your entries, they can file the CAPE Declaration on your behalf. Most brokers are charging a flat fee per refund file. If you have under 50 entries, self-filing is probably worth it; over 50, a broker is faster and reduces rejection risk. Either way, only the Importer of Record or an authorized broker can submit.
  4. Use AI to validate your CSV before upload. The CAPE template is a single-column Excel sheet with the header “Entry Number” and rows of entry numbers below. The most common rejection reason is bad CSV formatting, not bad data. Paste your draft CSV into Claude or ChatGPT with the CBP template description and ask the AI to flag any rows that don’t conform. This catches 90% of formatting errors before submission and saves a week of round-trips with CBP.
  5. Open the conversation with your suppliers. Email your top three suppliers a one-paragraph note this week: “Are you filing for IEEPA tariff refunds, and if so, are retailers going to see any benefit through pricing on shipments made during 2025?” Suppliers who refund nothing should get an honest reevaluation against alternatives like the multi-supplier platforms in Inventory Source or other U.S.-based suppliers.
  6. Map the refund into your Q3 forecast cleanly. Don’t book the money as gross profit. Book it as a reversal of the 2025 expense, with interest as separate interest income. If you’re using Finaloop or another ecommerce-specific accounting platform, this categorizes correctly by default. Tell your accountant the refund is coming and how you plan to book it. A 60-90 day timeline once your CAPE Declaration is accepted means the cash hits in late Q3 if you file now.
  7. Get personal eyes on your situation if it’s complicated. Tariff refunds plus a multi-supplier import structure plus 3PL relationships is the kind of situation that’s worth an hour of one-on-one mapping. If you want me to look at your specific import profile and walk through which refunds you can claim, my 1-on-1 coaching handles exactly this kind of operator-specific situation.

Frequently Asked Questions

How long does CBP take to actually send the refund after I submit the CAPE Declaration?
CBP says valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of the CAPE Declaration, unless a compliance concern requires further review. The clock starts when CBP accepts the file, not when you upload it. If your file gets rejected on initial validation, you go back to the start of the 60-90 day window once the resubmission is accepted.

Do I get interest on top of the principal refund?
Yes. CBP confirmed in its filing that certified refunds include interest, accrued from the date the duty was paid through the date the refund is certified. The interest rate is set under the standard federal underpayment/overpayment statute and adjusts quarterly. For most 2025 IEEPA duties, you’re looking at 8% to 10% annualized interest on the principal.

I sold my products through Amazon, Walmart, or another marketplace and never imported anything myself. Can I claim?
Almost certainly not directly. The Importer of Record on the entries paid the IEEPA duties, and only the IOR or an authorized broker can claim. If you bought your inventory from a U.S. wholesaler who imported it, the refund flows to that wholesaler first. The right move is to ask your wholesaler whether they’re filing and whether retailers will see any benefit through pricing, then decide whether to stay or switch.

I dropship and never take title to physical inventory. Does this affect me at all?
Indirectly, yes. Your suppliers’ landed costs are about to change retroactively, which means their pricing power is about to shift. Operators using U.S.-based suppliers who file aggressively for refunds may see margin breathing room as those suppliers pass some of the windfall back. Operators using suppliers who pocket the entire refund will see relative pricing get less competitive. Now is the time to have the supplier conversation.

What about the 10% global tariff that the trade court recently ruled illegal too?
That’s a separate refund track, not currently in CAPE Phase 1. The Court of International Trade ruled in May 2026 that the 10% global tariff was also illegally imposed, and CBP is in the process of figuring out how to handle that pool. Expect a Phase 2 or a separate channel later in 2026. The mechanics will look similar, but the eligibility window will be different.

I just got my LLC formed and I’m new to importing. Is this going to be an ongoing complication?
If you’re brand-new and your store hasn’t imported yet, you have no direct exposure to this round of refunds, but you will be operating in an environment where tariff structures are clearly being challenged in court more often. Build your import structure on the assumption that policies will change, which means keeping clean records and an ACH-enabled business account from day one. If you’re new and want the fundamentals first, the beginner guide walks through the foundational moves before you start sourcing.

Is this whole process worth doing for a refund under $5,000?
If you can self-file, yes. The CAPE Declaration takes maybe two hours of setup if you have your entry list ready and your ACH info confirmed. A $5,000 refund with interest is real money for most ecommerce operators. If you have to pay a broker $1,500 to file for a $5,000 refund, the math gets thinner but it’s still worth it once you factor in the interest. Below $2,000 in expected refund, I’d self-file or skip it depending on how organized your records are.

Where do I actually start? I’m overwhelmed.
Step one is logging into the ACE Portal and confirming your account info is current, including ACH banking. Step two is pulling your 2025 entry list. Step three is mapping out the broader tariff exposure on your specific SKUs. If you’d rather not do any of this yourself and you’d like a team that already handles import structure, supplier relationships, and the operational side of a high-ticket store, my turnkey service is built for exactly that.

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The CBP $85 billion refund pool is going to keep growing as more entries clear the validation process and Phase 2 opens for finally liquidated entries. The window won’t be open forever, and the operators who get organized this week, get their ACH info clean, and get their CAPE Declarations in queue, are the ones who see real cash hit their accounts in Q3 instead of watching it disappear back into Treasury. If you want the deep-dive backstory on how I think about regulatory surprises like this, subscribe to the YouTube channel for daily breakdowns. More breaking news coming later today.

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