U.S. Customs and Border Protection

Manufacturers Alliance reported that 76% of surveyed Phase 2 filers had received only partial refunds and 24% reported full refunds. It also reported that 54% of partially refunded companies received no CBP explanation, error code, or line-level detail for the remaining amount.

CBP reported that approximately $136.6 billion in potential and certified refunds had been accepted for CAPE processing as of October 2. Of that amount, approximately $126 billion in duties and interest had been refunded or sent for Treasury disbursement.

U.S. Customs and Border Protection deployed CAPE Phase 3 for plaintiffs in more than 4,000 cases in which the court had entered an order. Phase 3 permits those plaintiffs to file CAPE declarations for finally liquidated entries.

U.S. Customs and Border Protection published a Federal Register notice concerning an information collection request for CAPE refund worksheets. The notice states that CBP will submit the request to the Office of Management and Budget for review and approval under the Paperwork Reduction Act.

The second 100,000-metric-ton tranche for other countries or areas opened on October 1, 2026. The tranche was scheduled to close on October 30, 2026.

The fourth 20,000-metric-ton tranche of the Argentine lean-beef-trimmings quota opened on October 1, 2026. The tranche was scheduled to close on December 31, 2026.

U.S. Customs and Border Protection updated its IEEPA-duty-refund guidance with instructions for correcting importer information on CBP Form 5106. CBP said licensed customs brokers with valid powers of attorney may make updates through ABI Action Code U, while importers may update information through the ACE Portal.

CBP said enhanced enforcement would commence on September 18, 2026, including immediately voiding importer-of-record numbers carrying inaccurate information on CBP Form 5106.

U.S. Customs and Border Protection notified the Court of International Trade that CAPE Phase 3 would deploy on October 6, 2026. Plaintiffs that submitted a valid importer-of-record number to CBP by July 30, 2026, would be eligible to file Phase 3 declarations beginning on that date.

CBP reported that CAPE had accepted approximately $134.7 billion in potential and certified refunds for processing. It said approximately $122 billion in duty refunds and interest had been certified and transmitted to the U.S. Treasury for payment.

Revisions to the Section 338 tariff schedule under the U.S. motor-vehicles proclamation took effect on September 15, 2026. The changes applied to goods entered for consumption or withdrawn from warehouse for consumption on or after that date.

FedEx said it had begun issuing IEEPA tariff refunds, including interest, to shippers and customers who originally bore the charges. It identified U.S. Customs and Border Protection as the source of the interest received.

U.S. Customs and Border Protection had certified approximately $107 billion in IEEPA-duty refunds through August 21, 2026. The amount was about 64 percent of the $166 billion collected.

The Court of International Trade ordered CBP to reliquidate plaintiffs' entries that had been liquidated for more than 80 days without regard to IEEPA duties. The order applied after CBP accepted a plaintiff's CAPE declaration.

CBP had sent approximately $86.3 billion in refunds to the Department of the Treasury for disbursement. The Court of International Trade recited that status in its July 15 order.

Apple disclosed that it had applied for refunds of tariffs paid through CBP processes. It said tariff refunds contributed to product gross-margin improvement during the quarter.

Tapestry estimated that its probable tariff refund was $114.7 million and recorded that amount as a receivable. It reported receiving $2.1 million in fourth-quarter cash refunds.

DOJ filed notices of appeal at the Federal Circuit arguing the trade court cannot order refunds to importers who never sued, the CASA argument it had flagged in March. At a June 9 hearing CBP's trade chief Susan Thomas testified that CAPE had accepted claims covering about $90 billion of the $166 billion collected and transmitted about $23 billion to Treasury, having processed refunds on nearly 8.5 million entries in six weeks. Entries liquidated more than 80 days earlier, worth perhaps $30 billion, remained contested.

CBP reported that approximately $20.6 billion in duty and interest refunds had been completed using CAPE. The declaration was filed in Euro-Notions Florida, Inc. v. United States. Four days later CBP corrected an earlier estimate of refunds in process to $25.46 billion, clarifying that a prior figure of about $35.46 billion had been overstated.

Gregory Hoffert and Prashant Sharan filed a proposed class action against Nintendo of America. They alleged Nintendo could recover tariff payments from consumers through higher prices and from the federal government through refunds.

Customs and Border Protection opened the Consolidated Administration and Processing of Entries tool inside the Automated Commercial Environment so importers and brokers could file a CSV list of entries and receive consolidated refunds with interest by ACH instead of entry-by-entry claims. Phase 1 covered unliquidated entries and entries within 80 days of liquidation; reconciliation-flagged entries followed on June 29, and finally liquidated entries were left to a later phase. By mid-May more than 126,000 declarations covering 15 million entries had been accepted.

The Court of International Trade ordered that finally liquidated entries be reliquidated without regard to IEEPA duties. The order concerned entries for which liquidation was final.

Judge Richard Eaton of the Court of International Trade, in a case brought by importer Atmus Filtration, ordered Customs to liquidate unliquidated entries without IEEPA duties and to reliquidate entries whose liquidation was not yet final, and held that the relief reaches all importers because the trade court's exclusive nationwide jurisdiction is not subject to the limits on universal injunctions in Trump v. CASA. The government, which had argued that only the 2,000-plus companies with claims on file should be refunded, was denied a stay and said it would appeal.

Three executive orders signed on February 1, 2025 used the International Emergency Economic Powers Act, a 1977 sanctions statute never before used for tariffs, to impose duties on the three largest U.S. trading partners, citing fentanyl trafficking and migration as a national emergency. The China order took effect February 4; the Canada and Mexico duties were paused for a month and then imposed in March. These trafficking tariffs became one of the two sets of IEEPA duties later struck down.