The Court of International Trade held a status conference this week regarding the ongoing IEEPA refund process, and the hearing provided the clearest picture yet of where refunds stand today.

The biggest takeaway: no one argued that importers are not entitled to refunds.

Instead, the discussion focused on how CBP will continue expanding the refund process to ensure all eligible importers can receive refunds of unlawfully collected IEEPA duties, plus interest.

Refund Processing Continues to Accelerate

CBP reported that approximately $166 billion in IEEPA duties were collected from more than 330,000 importers across approximately 53 million entries.

As of the hearing:

• More than 16 million entries have already been submitted through CAPE.
• Approximately $95 billion in refunds is currently moving through the CAPE process.
• More than $23 billion has already been transmitted to Treasury for payment.
• CBP expects that amount to reach approximately $40 billion by the end of June.

To put the scale of the effort into perspective, CBP processed refunds on approximately 338,000 entries during all of fiscal year 2025. The IEEPA refund program involves more than 53 million entries.

Phase 2 Launching June 29

CBP confirmed that CAPE functionality for reconciliation entries is expected to be deployed on June 29, 2026.

This phase represents approximately:

• 3 million entries
• $28.7 billion in IEEPA duties

Once Phase 2 is available, CBP estimates that more than 80% of all IEEPA duties collected will be eligible for refund through CAPE.

Phase 3 Expected by End of July

CBP also provided a timeline for addressing finally liquidated entries.

The agency estimates that this category represents approximately:

• $11.4 billion
• Approximately 9% of all IEEPA duties collected

CBP expects the next CAPE buildout addressing these entries to be completed by the end of July.

Remaining Categories

Several additional categories remain outside the current CAPE process, including:

• Drawback claims
• Certain reconciliation scenarios
• Administrative protests
• Other specialized entry types

These categories collectively represent approximately $18.9 billion in potential refunds.

What Importers Should Know

While many businesses are still waiting for refunds, the information presented to the court shows that the refund process continues to move forward and expand.

The court, CBP, and the government all appear to be working toward the same ultimate goal: ensuring that every American business entitled to an IEEPA refund has a path to receive that refund.

Project TERRA will continue monitoring developments, tracking refund progress, and providing updates as additional information becomes available.