Trump Tariff Refunds 2026: Who Qualifies for the $122 Billion IEEPA Payback — and How Importers Claim It

One hundred and twenty-two billion dollars. That is how much in tariff refunds — duties plus accumulated interest — the United States had completed, reconciled and transferred from Customs and Border Protection to the Treasury as of September 11, 2026, after the Supreme Court struck down the IEEPA tariffs. CBP has accepted roughly $134.7 billion for processing, and interest keeps accruing at about $650 million per month, according to 24/7 Wall St. Yet many importers still have money unclaimed, roughly one claim in seven has been rejected at some stage, and scammers are circling whoever moves slowly. Here is what the ruling did, who qualifies, and how the money is actually claimed.

What the Supreme Court Actually Decided

On February 20, 2026, the US Supreme Court ruled 6–3 in Learning Resources, Inc. v. Trump, 607 U.S. 229, that the International Emergency Economic Powers Act — IEEPA, a 1977 statute that hands the President economic tools to use against declared national emergencies — does not authorize the President to impose tariffs. As the legal analysis published by JD Supra explains, the dispute turned on whether IEEPA's grant of power to regulate importation could be stretched to cover levying duties. The majority concluded it could not: a tariff is a tax on imports, and the power to impose such taxes was never conferred by the emergency statute. The commentary from the American Enterprise Institute on what the ruling says about judicial power adds a second dimension to the story, arguing the Court placed itself directly between the White House and one of the most consequential economic levers of the previous two years — a decision with implications that reach well beyond customs law.

The aftermath moved quickly. President Trump terminated the tariffs the Court had invalidated and imposed a new global 10 percent duty resting on different legal authority, as DW reported the day after the ruling, and later applied 50 percent waves of duties on goods from Canada. By August 2026, Reuters reported that 25 states had filed suits of their own, keeping the broader trade fight alive in the courts. One point matters more than any other for anyone holding paid customs entries from the past two years: Section 301 forced-labor tariffs remain in force and are now facing a new legal test of their own. In plain terms, not all tariffs are refundable — only the ones that had been imposed under IEEPA.

For importers, the ruling converted certain duties already paid into refundable overpayments. Every refund dollar in the program described below traces back to that single six-to-three decision, which is why getting the eligibility question right — IEEPA duty versus everything else — determines whether a filing succeeds or bounces.

Where the $122 Billion Went: A Timeline

The refund operation started as a trickle and became one of the largest transfers from the federal government to the business community in recent memory. Each milestone below was reported as it happened, and the escalation is worth seeing in one place:

Two figures on this table are routinely confused. "Accepted for processing" is money CBP has agreed to work through; "completed" is money actually reconciled and paid. The $122 billion milestone represents the completed pool as of September 11, while the accepted pool stood near $134.7 billion, with the difference still moving through the machinery. Interest is the reason delay is expensive: it accrues at roughly $650 million per month on amounts owed but not yet paid, per 24/7 Wall St's September 24 accounting of the program.

The trajectory also tells you something about capacity. Going from $35.5 billion accepted in mid-May to $85 billion accepted exactly two weeks later, then to $100 billion actually paid out by early August, means CBP scaled its processing dramatically over the summer. That is encouraging for importers who have not yet filed — the machinery demonstrably works at scale — but it does not change the rules of who may file, what is covered, or how the payout reaches your bank account.

Who Qualifies — and What Is Not Refundable

The short version of eligibility: an importer that paid duties imposed under IEEPA authority, with the refund declaration filed by the Importer of Record or by a licensed customs broker acting for that importer. CBP's official rules page states this without exceptions, and it is the first thing to verify before spending time on a claim. If a third party approaches you promising to "file with CBP on your behalf" in its own name, that promise conflicts with the published rules.

One wrinkle deserves special attention. For imports from the agreement countries — the European Union, Japan, Korea and Switzerland — only the 10 percent IEEPA portion of the border charge is refundable. The 5 percent Column 1 portion, the piece that sits under the 15 percent cap arrangement, stays owed and collected. Column 1 rates are the standard duty framework of the US tariff schedule, and they were untouched by the Supreme Court's decision. Importers from these corridors should therefore expect a split refund, not a full one, and should model their cash recovery accordingly.

The refund program also sits inside a wider global rebalancing of how governments tax cross-border commerce. European policymakers, for instance, have been tightening EU customs duties on low-value parcels, moving in the opposite direction from the American court-ordered giveback — a useful reminder that a duty position can shift in either direction depending on the jurisdiction, and that today's refund regime coexists with new levies arriving through other doors.

If you imported goods into the United States while the IEEPA tariffs were in force and want a specialist to review your customs position before the interest clock and the processing queues move further, you can book a consultation at https://truescho.com/en/consultants.

Filing Through CAPE Step by Step

Refunds run through CAPE, the dedicated system CBP built after the ruling. It launched on April 20, 2026; Phase 2 of the guidance was published on June 29, 2026; and Phase 3 launched on October 6, 2026 — literally the day before this article was written. Because the system has evolved in phases over less than six months, importers should work from current official materials rather than cached guides or commentary written against the April version of the process.

Who May File

Only two parties can submit a CAPE declaration: the Importer of Record, or a licensed customs broker filing on that importer's behalf. No consultant, law firm or "recovery agency" can file in its own name. Outsiders can help you assemble documentation and check eligibility, but the declaration itself has to travel through one of those two channels — a rule that simultaneously protects the integrity of the process and explains why so many third-party offers deserve a skeptical second look.

The Filing Steps

In practice the workflow runs like this: confirm which of your entries carried IEEPA duties; verify that your entity details as Importer of Record match what CBP already holds; prepare the declaration inside CAPE; submit it; and monitor status through to payout. On the account side, CBP publishes an official ACE and ACH enrollment video that walks through the setup, and the agency's IEEPA duty refunds fact sheet summarizes the declaration requirements. Treat those two pages as the canonical references; everything else — this article included — is a map, not the territory.

The 60–90 Day ACH Payout

Refunds are paid exclusively by ACH transfer, and CBP's guidance puts the payout window at 60 to 90 days. Two practical consequences follow. First, an importer without ACH enrollment needs to fix that before filing, or an approval will sit with nowhere to go. Second, cash-flow planning should assume the longer end of the range: as the documented claimant experiences below show, the calendar does not always cooperate even when the paperwork is right.

The 9,999-Line Cap

Each CAPE declaration is capped at 9,999 line items. For a large importer with thousands of entries spread across two years of IEEPA tariffs, that means splitting the claim across multiple declarations and keeping a disciplined reconciliation of what was filed where. The cap is administrative, not a limit on entitlement — but a claim assembled without tracking line items across splits is exactly the kind of filing that stalls in processing.

Five Mistakes That Get Claims Rejected

The program's early months were rougher than the headline numbers suggest. Shortly after the April 2026 launch, only about 3 percent of line items had been refunded. By May 2026, 15 percent of claims were being rejected. In a case documented by the Wall Street Journal on October 4, 2026, an importer needed nine months to recover $164,000. And in June 2026 the Department of Justice appealed a Court of International Trade order from Judge Eaton that would have required blanket refunds — a reminder that the legal perimeter of the program was still being contested even as money flowed out the door.

Against that backdrop, the rejection patterns consistent with CBP's published rules are largely avoidable:

1. Filing from the wrong party. A declaration submitted by anyone other than the Importer of Record or a licensed customs broker fails at the threshold.
2. Claiming non-IEEPA duties. Section 301 duties, the retained 5 percent Column 1 portion for agreement countries, and the post-ruling global 10 percent duty all sit outside the program. Mixing them into a declaration contaminates the filing.
3. Missing or broken ACH enrollment. With ACH as the only payout rail, banking errors convert approvals into stale files.
4. Data mismatches against CBP's entry records. Entry numbers, line-item values and entity details that do not match what CBP already holds are a classic trigger for rejection and rework in duty processing.
5. Mismanaging the 9,999-line cap. Duplicated or orphaned line items across split declarations create reconciliation failures that delay payment even when the underlying claim is valid.

None of these requires legal genius to avoid. They require care, current data, and — for high-value or high-volume claims — a licensed customs broker who files these declarations for a living and knows what the system will and will not accept.

An Official Scam Warning from CBP

CBP has issued an unusually blunt warning: anyone charging a fee in CBP's name is running a scam. The agency's CAPE refund fraud solicitation alert exists because fraudulent solicitation followed the program's launch, targeting importers with legitimately large claims pending and betting that urgency would override caution.

Source: U.S. Customs and Border Protection seal — Wikimedia Commons

The practical hygiene rules follow directly. Verify any broker's license before engaging them. Treat unsolicited "refund processing" invoices as hostile until proven otherwise. Confine your filings to the CAPE environment itself, and treat cbp.gov — not a lookalike domain, not an intermediary's portal — as the only authoritative source of program rules. Large sums, bureaucratic delay and a sense of deadline pressure are precisely the conditions under which payment fraud thrives, and this program currently offers all three in quantity.

The Big Names Got Paid: Dollar Tree and FedEx

The corporate results make the scale concrete. Dollar Tree received $369 million in tariff refunds plus $14 million in interest, as Insider Monkey reported on August 28, 2026 — and while some press coverage rounded this to "about $400 million," the precise figure is $369 million of refunds plus $14 million of interest. The accounting impact was material: refunds boosted earnings per share by $1.31 of the quarter's $2.70, per ainvest's report of October 3. When a single recovery item carries nearly half of a quarter's per-share earnings, it explains why finance teams across import-heavy sectors have been so focused on this program.

The logistics carriers handled a different version of the same problem: duties they had advanced on behalf of customers. FedEx is returning $800 million to customers starting in August 2026, per the June 2026 reporting by WWD and Supply Chain Dive, and by April 2026 UPS, FedEx and DHL had each publicly detailed their approaches to handling tariff refunds for customers. If your freight moved with one of the big three during the IEEPA period, checking whether a pass-through refund is due to you belongs on the same checklist as your own CAPE filing — the money may be sitting with your carrier rather than with CBP.

Does Any of It Reach Consumers?

Legally, the refunds went to importers of record — not to shoppers. Whether any portion reaches consumers is a live question, and in at least one case it is now a courtroom question. Yahoo Finance reported on September 9, 2026 that Dollar Tree faces a lawsuit alleging it kept tariff-driven price increases in place without passing the refunded difference back to shoppers. The allegation is unproven and the case is ongoing, but it frames the issue precisely: when prices rise because of a duty, and the duty is later refunded, who owns the difference?

The honest answer is that pass-through economics are messy in both directions. Businesses that never fully passed tariffs into prices also never fully absorbed them at refund time, and refund cash rarely arrives with a label saying who ultimately bore the original cost. There are echoes here of other mass-recovery programs where the money stops one layer short of the end buyer — the long-running card interchange settlement saga is the classic example of recoveries that reward whoever files, not necessarily whoever paid. And for businesses still deciding what to do with refund cash, the wider cost environment — including the pressures building on US small-business budgets heading into 2027 — argues for treating it as working capital to be allocated deliberately rather than as a windfall.

The Bottom Line Before You File

Treat this program with the respect its size deserves. The money is real: $122 billion completed and transferred, roughly $134.7 billion accepted for processing, interest compounding at roughly $650 million a month on what remains. So are the pitfalls: a 15 percent rejection rate as of May 2026, a documented nine-month fight to recover $164,000, and a fraud wave serious enough that CBP published a dedicated alert. Move as the Importer of Record or through a licensed customs broker, file inside CAPE, keep every line item traceable, and verify every rule against cbp.gov rather than against intermediaries — customs enforcement is tightening in many corridors at the same time as this refund flows, as Europe's clampdown on low-value parcels shows, and a careful position review is always cheaper than a rejected filing. If you would rather have a specialist sanity-check your eligibility and documentation before you submit anything, you can review advisory engagements at https://truescho.com/en/opportunities.

Frequently Asked Questions

Q: Who is eligible for IEEPA tariff refunds in 2026?

Any business that paid duties imposed under IEEPA authority and files through the proper channel: the Importer of Record, or a licensed customs broker acting on the importer's behalf. For the agreement countries — the EU, Japan, Korea and Switzerland — only the 10 percent IEEPA portion is refundable; the 5 percent Column 1 portion stays owed. Section 301 duties and post-ruling tariffs are excluded entirely.

Q: How do I file a CAPE declaration?

The declaration is filed in CBP's CAPE system by the Importer of Record or a licensed customs broker — no other party may submit one. You identify the entries carrying IEEPA duties, prepare the declaration with entity and line-item data matching CBP's records, keep each declaration at or below 9,999 line items, and ensure ACH enrollment so the refund has somewhere to land. CBP's official fact sheet walks through the requirements.

Q: What did the Supreme Court decide in Learning Resources v. Trump?

On February 20, 2026, the Court ruled 6–3 in Learning Resources, Inc. v. Trump, 607 U.S. 229, that IEEPA — the 1977 emergency-powers statute — does not authorize the President to impose tariffs. The invalidated tariffs were terminated, and refunds of the IEEPA-based duties flow through CBP's program. Duties resting on other legal authorities were not affected by the ruling.

Q: How long do CBP refunds take via ACH?

CBP's guidance puts the payout window at 60 to 90 days, paid exclusively by ACH transfer. Real-world timelines can run longer: shortly after launch only about 3 percent of line items had been refunded, and the Wall Street Journal documented a case that took nine months to recover $164,000. Plan cash flow around the long end of the range.

Q: Which tariffs are refundable and which still stand?

Refundable: the IEEPA reciprocal and trafficking-related tariffs, including the 10 percent IEEPA portion paid on goods from the EU, Japan, Korea and Switzerland. Not refundable: the 5 percent Column 1 portion under the 15 percent cap, the new global 10 percent duty imposed after the ruling, the 50 percent waves on Canada, and Section 301 forced-labor tariffs, which remain in force and face a separate legal test.

Q: Is anyone charging fees to file IEEPA refunds?

Yes — and CBP has issued a formal warning that anyone charging a fee in CBP's name is committing fraud. Legitimate costs come from licensed customs brokers or advisors you engage directly, never from "CBP" itself. Verify broker licenses, ignore unsolicited refund-processing invoices, and rely only on cbp.gov and the CAPE system for program rules.