IEEPA Tariff Refund Timeline

From the first IEEPA tariffs in February 2025 to the Supreme Court's ruling and the CAPE portal launch in 2026 — a chronological record of the key events shaping the refund process.

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  1. IEEPA tariffs imposed on Canada and Mexico

    President Trump signed executive orders imposing 25% tariffs on Canadian and Mexican imports under the International Emergency Economic Powers Act, citing a national emergency related to fentanyl trafficking. These were the first tariffs imposed under IEEPA authority since the law was enacted in 1977.

  2. IEEPA tariffs expanded to China and "reciprocal" partners

    The administration extended IEEPA tariff authority to cover Chinese imports, imposing escalating surcharges throughout the spring and summer of 2025. A "reciprocal tariff" order imposed duties on goods from dozens of additional trading partners based on their own tariff rates on U.S. exports.

  3. China tariff escalation — rates climb through the year

    IEEPA tariff rates on Chinese goods escalated multiple times, ultimately reaching levels that, combined with existing Section 301 duties, placed surcharges exceeding 100% on some categories. Importers began facing severe cost pressures and a wave of product repricing.

  4. Legal challenges consolidated in the Court of International Trade

    Multiple importers and trade associations filed challenges in the Court of International Trade arguing that IEEPA did not authorize tariffs. The CIT consolidated these cases for coordinated briefing and argument. Learning Resources, Inc. — a Northbrook, Illinois educational toy maker — became the lead plaintiff.

  5. CIT rules IEEPA tariffs unconstitutional

    The Court of International Trade issued its ruling in Learning Resources, Inc. v. Trump, holding that Congress did not grant the President authority to impose tariffs under IEEPA. The administration immediately appealed to the Federal Circuit, which stayed enforcement of the CIT's order pending appeal.

  6. Federal Circuit affirms CIT ruling; Supreme Court takes the case

    The Federal Circuit affirmed the CIT's holding on an expedited basis, and the Supreme Court granted certiorari within days — an unusually fast grant that signaled the Court's desire to resolve the question before the 2026 filing season.

  7. Supreme Court rules 6-3 — IEEPA tariffs are unlawful

    The Supreme Court issued its decision in Learning Resources, Inc. v. Trump, affirming the lower courts in a 6-3 opinion authored by Chief Justice Roberts. The majority held that IEEPA's authorization for the president to "regulate" foreign commerce does not include the power to tax it through import tariffs. Three justices dissented on separation-of-powers grounds. The ruling immediately invalidated all IEEPA-imposed tariffs.

  8. CIT issues comprehensive reliquidation order

    The Court of International Trade issued a follow-up order directing CBP to reliquidate all affected entries and return collected IEEPA duties. The order specified that CBP must establish a refund mechanism and publish guidance within 30 days.

  9. CBP publishes four-step refund framework

    U.S. Customs and Border Protection published its framework for the IEEPA refund process: (1) claim submission via a new CAPE portal, (2) CBP duty recalculation, (3) entry reliquidation, and (4) ACH refund disbursement. CBP confirmed a target portal launch date of April 20, 2026.

  10. CAPE portal launches — Phase 1 claims open

    The Customs Automated Processing Environment (CAPE) portal went live within ACE. Phase 1 accepts claims for unliquidated entries and entries liquidated within the prior 80-day window. CBP estimated a 60-to-90-day processing timeline from submission to refund disbursement.

  11. First week of CAPE filings; early technical issues reported

    Thousands of importers and customs brokers began submitting Phase 1 claims. Trade publications reported intermittent portal slowdowns, ACH validation delays, and CSV rejection issues for whitespace encoding. CBP confirmed awareness of the issues and indicated fixes are in progress.

  12. Phase 2 expected — protested and older entries

    CBP has indicated that a second phase of CAPE will address entries outside Phase 1's scope, including entries with pending protests, entries liquidated more than 80 days ago without a protest on file, and complex cases involving antidumping and countervailing duties. No specific launch date has been announced.

Sources: U.S. Supreme Court (Learning Resources, Inc. v. Trump, Feb. 20, 2026); U.S. Court of International Trade orders, March 2026; CBP CAPE framework documentation, March 12, 2026; trade press coverage (NerdWallet, CBS News, NewsNation), April 2026.

This timeline is updated as significant events occur. Last updated: April 27, 2026.

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