CBP released its latest status report on IEEPA refund processing at the end of March. The numbers are the most comprehensive data set we’ve had since the Supreme Court ruling, and they tell a story that’s both encouraging and sobering — depending on your position in the queue.
Here’s what the data shows, what it means for processing timelines, and what importers should take away from the numbers.
The Raw Numbers
CBP’s report covers processing activity from the CAPE system launch through March 28, 2026.
Volume Metrics
| Metric | Number |
|---|---|
| Total CAPE declarations received | 42,800 |
| Declarations accepted (passed validation) | 30,100 |
| Declarations rejected (failed validation) | 8,200 |
| Declarations pending validation | 4,500 |
| Declarations in active processing | 12,400 |
| Refunds approved and issued | 4,800 |
| Refunds in payment processing | 2,100 |
| Total refund value issued | $780M |
| Total refund value approved (including pending payment) | $1.14B |
Staffing and Capacity
| Metric | Number |
|---|---|
| CBP staff assigned to IEEPA processing | ~2,500 |
| Average declarations processed per examiner per day | 3.2 |
| Daily system capacity (current) | ~800 declarations |
| Projected capacity after scaling | ~1,500 declarations |
Rejection Analysis
| Rejection Reason | Percentage |
|---|---|
| Entry number mismatch | 32% |
| Duty amount discrepancy | 24% |
| Liquidation status mismatch | 19% |
| HTS code formatting error | 14% |
| Authorization/IOR issues | 7% |
| Other | 4% |
What the Numbers Tell Us
Processing Speed: Better Than Expected (For Now)
The 4,800 refunds issued in roughly four weeks of operations implies a processing rate of approximately 1,200 claims per week — or about 240 per business day. That’s slightly above the rate CBP’s staffing would suggest (2,500 staff × 3.2 claims/day ÷ factor for management and support = approximately 200-250 claims/day).
This pace is encouraging because it suggests CBP is meeting or slightly exceeding its operational capacity targets. However, it’s important to note that these early claims are likely the simplest — clean PSC-eligible entries with straightforward data. As the queue fills with more complex claims (protests, mixed portfolios, entries requiring CIT coordination), processing per claim will take longer.
The Rejection Rate: 19% Is High
Nearly one in five declarations is being rejected for data validation errors. That’s a significant inefficiency in the system — each rejection requires the importer (through their broker) to identify the error, correct the data, and resubmit. More importantly, rejected declarations lose their queue position upon resubmission.
The rejection data reinforces what we’ve been emphasizing: data quality is the primary determinant of processing speed. Importers who took time to prepare and validate their data against ACE records before filing are experiencing smooth processing. Those who rushed are cycling through rejections and falling further behind.
The most common rejection — entry number mismatch (32%) — is typically a data entry error that’s easily preventable with proper verification. If you’re preparing to file, triple-check your entry numbers against your ES-003 report.
The Scale Problem: $780M vs. $166B
The $780 million in refunds issued through March 28 represents approximately 0.47% of the estimated $166 billion total. At the current processing rate, clearing the entire backlog would take approximately:
- $780M issued over ~4 weeks = ~$195M/week
- $166B ÷ $195M per week = ~851 weeks = ~16.4 years
Obviously, that’s not going to happen. The rate will increase as:
- Staffing scales. CBP has requested supplemental budget for additional processing staff. If approved, capacity could double by Q4 2026.
- Automated processing activates. CBP plans a high-volume auto-approval mode for straightforward claims. This could process thousands of claims daily without examiner review.
- Batch processing improves. The April batch upload feature will increase declaration submission volume, keeping the queue fed as processing capacity grows.
- Process maturation. Examiners will get faster as they process more claims and develop expertise.
A more realistic projection: with capacity scaling, automated processing, and process maturation, CBP may be able to process $2-5 billion per month by late 2026. At $5B/month, the full backlog would clear in approximately 33 months (by mid-2029). At $2B/month, it would take 83 months (by mid-2033).
These projections explain why queue position matters so much. The difference between filing in Q2 2026 and filing in Q4 2026 could be 6-12 months of additional wait.
The Staffing Bottleneck
At 3.2 declarations per examiner per day, each claim requires approximately 2.5 hours of examiner time. That’s a lot — and it suggests the current process is heavily manual, with examiners reviewing each claim individually.
For context, 2,500 staff handling IEEPA processing is a significant allocation — CBP’s total workforce is approximately 60,000. Dedicating 4% of the entire agency to a single processing task is substantial and indicates the government takes the refund obligation seriously.
But it’s not enough. At current staffing, processing all claims would take years even with efficiency improvements. The supplemental budget request — which would add an estimated 1,000-1,500 additional processing staff — is critical to achieving reasonable timelines.
Average Claim Size Signals
The $780M over 4,800 claims yields an average of approximately $162,500 per claim. This tells us several things:
- Small claims (under $50,000) are likely underrepresented in early filings — smaller importers may not have started the process yet
- Very large claims (over $5M) are also underrepresented — complex portfolios take longer to prepare and file
- The mid-market ($100K-$500K) is driving early CAPE volume
If your claim is under $50,000, you may be wondering whether it’s worth the effort. The answer is almost certainly yes, especially if your entries are PSC-eligible — the filing cost is minimal and the recovery is straightforward. See our guide for small importers.
Implications for Your Timeline
Based on the CBP data, here’s how to think about your specific timeline.
If You’ve Already Filed (and been accepted)
Your position in the queue is established. At current processing rates, expect:
| Queue Position | Estimated Processing Time |
|---|---|
| First 10,000 declarations | 4-8 weeks from acceptance |
| 10,000-20,000 | 8-16 weeks from acceptance |
| 20,000-30,000 | 16-24 weeks from acceptance |
| 30,000+ | 6+ months from acceptance |
These estimates assume current processing rates. If CBP scales staffing and activates automated processing, times could compress significantly.
If You’re About to File
You’ll enter the queue behind approximately 30,000-35,000 accepted declarations. At current rates, that puts your processing start at approximately 5-7 months from filing. With capacity scaling, it could be 3-5 months.
The message: file now. Every week of delay adds to your wait.
If You Haven’t Started
You’re looking at the back of an already-long queue, plus the time to prepare your data, coordinate with your broker, and file. Realistic total timeline from starting today to refund: 8-18 months for PSC-eligible entries, 18-36+ months for protest entries.
The cost of waiting analysis becomes more concrete with these numbers. At a 10% cost of capital, a $500,000 refund delayed 12 months beyond what early action would have achieved costs you $50,000 in opportunity cost.
What CBP Didn’t Report (But Should Have)
Processing Times by Claim Type
CBP’s report aggregates all claim types. We don’t have separate processing statistics for PSC claims vs. protest claims vs. CIT-ordered claims. This matters because different claim types likely have very different processing speeds. Industry groups have requested this disaggregation in future reports.
Geographic Distribution
We don’t know whether processing is distributed evenly across ports of entry or concentrated at certain locations. If your entries were filed at a busy port (Los Angeles/Long Beach, Newark, Houston), there may be additional delays at the local level.
Resubmission Success Rates
Of the 8,200 rejected declarations, how many have been successfully resubmitted? If many rejected filers are struggling to correct their data, the effective processing rate is lower than the headline numbers suggest.
Interest Calculations
The report doesn’t address how interest under 19 U.S.C. Section 1505 is being calculated on issued refunds. Are refunds including interest from the date of deposit (the government’s stated position), or are interest calculations being handled separately? Importers who have received refunds should verify that interest is included.
What the Data Means for Different Importer Segments
The aggregate numbers tell one story. The segment-level implications tell a more nuanced one.
Large Importers ($50M+ Annual)
You likely have exposure in the millions and a complex portfolio requiring multiple recovery paths. The good news: the processing data shows CBP can handle complex claims — it just takes longer. The bad news: your position in the queue matters more because your processing time per claim will be higher.
Key action: If you haven’t already, engage professional advisory to manage the complexity. The cost is marginal relative to your exposure, and the DIY approach at this scale is risky. Consider a split strategy to generate immediate capital on complex entries while filing straightforward entries through CAPE.
Mid-Market Importers ($5M-$50M Annual)
You’re in the sweet spot for CAPE processing: portfolios large enough to matter financially but small enough to process efficiently. The 35-day average PSC processing time is very achievable for well-prepared mid-market filings.
Key action: Validate your data and file immediately. Your portfolio is likely manageable enough for either DIY or professional advisory, but don’t let the decision between those two approaches delay your filing. File first, optimize later.
Small Importers ($1M-$5M Annual)
Your per-entry processing experience should be similar to the average — there’s nothing in the data suggesting small claims are deprioritized. The challenge is that your total refund may be smaller, making the administrative effort a larger percentage of the recovery.
Key action: Focus on PSC-eligible entries first — they’re the cheapest and fastest to recover. For entries requiring protests, evaluate whether the broker filing costs justify the recovery on a per-entry basis.
Micro Importers (Under $1M Annual)
The data suggests you’re underrepresented in early CAPE filings. Many micro importers haven’t yet started the process, either because they don’t know they’re eligible or because they believe the amounts are too small. The processing data shows that small claims process at the same speed as larger ones — there’s no penalty for being small.
Key action: Check your eligibility and at least request an Impact Assessment. You may be surprised by your total exposure.
Comparing CBP’s Numbers to Industry Estimates
Several industry organizations have published their own estimates of IEEPA refund processing capacity and timelines. Here’s how CBP’s actual numbers compare:
| Metric | NCBFAA Estimate (Feb 2026) | AAEI Estimate (Mar 2026) | CBP Actual (Mar 2026) |
|---|---|---|---|
| Initial processing rate | 500-800/week | 800-1,200/week | ~1,200/week |
| Rejection rate | 25-30% | 15-20% | ~19% |
| Average PSC processing time | 45-60 days | 30-45 days | ~35 days |
| Total queue clearance | 36-48 months | 24-36 months | TBD (data insufficient) |
CBP’s actual performance is outpacing the more conservative industry estimates. The initial processing rate and PSC processing time are both better than the NCBFAA projected. The rejection rate falls between the two estimates, suggesting the importance of data quality was neither overestimated nor underestimated.
This is encouraging for importers projecting their individual timelines. If the trend continues, total queue clearance may fall toward the lower end of industry projections — closer to 24 months than 48.
Our Recommendations Based on This Data
Recommendation 1: Prioritize Data Quality Over Filing Speed
The 19% rejection rate is a clear signal. A rejected declaration costs you weeks of processing time and queue position. Spend the time to validate your data before filing — it will pay off in faster total processing.
Recommendation 2: File PSC-Eligible Entries First
PSC claims are moving through the system fastest. If you have both unliquidated and liquidated entries, file PSC-eligible entries immediately and prepare protest entries in parallel.
Recommendation 3: Consider the Split Strategy
The processing data makes the split strategy more compelling. Sell your most complex or at-risk entries for immediate capital and file your clean entries through CAPE. This optimizes both speed and total recovery.
Recommendation 4: Monitor CBP Scaling
The supplemental budget request and automated processing activation will be the two biggest factors in CAPE processing acceleration. Watch for Congressional action on CBP appropriations and CBP announcements on auto-processing activation.
Recommendation 5: Plan for the Long Tail
Even with accelerated processing, the full $166 billion won’t be refunded quickly. Some claims — particularly those involving CIT litigation, complex documentation, or multiple recovery paths — will take years. Build this into your financial planning.
If you have entries that will be in the queue for 12+ months, consider whether the time value calculation justifies selling those entries for immediate capital. The processing data now gives you a more reliable basis for estimating your wait time, which makes the government-vs-claim-sale decision more informed than it was a month ago.
Recommendation 6: Verify Your Refund Amounts
If you’ve already received a refund, verify the amount against your expectations. Specifically check:
- Does the refund match the IEEPA duty amounts on the corresponding entries?
- Is statutory interest included (it should be)?
- Are there any unexplained deductions or adjustments?
Report discrepancies to your broker or advisory firm immediately. Early identification of calculation errors allows for correction while the claim is still active in CBP’s system. Waiting until after all refunds are issued makes resolution more difficult.
Recommendation 7: Get in the Queue
This is the simplest recommendation and the most important. Every data point in this report argues for filing sooner rather than later. The queue is growing, processing takes time, and your position determines when you get paid.
Get your free Impact Assessment →
What to Watch in the Next Status Report
CBP has not committed to a regular reporting schedule, but industry groups are pushing for monthly releases. When the next report comes, here are the key data points to watch:
- Processing rate trend: Is the ~1,200 claims/week rate increasing, stable, or declining? An increasing rate suggests capacity scaling is working. A declining rate suggests complexity is slowing examiners down as more difficult claims reach the front of the queue.
- Rejection rate trend: Is the ~19% rejection rate improving as filers learn the system? A decreasing rate suggests data quality education is working. A stable or increasing rate suggests systemic issues that may require CAPE interface improvements.
- Average refund size: If the average moves up, larger importers are entering the queue. If it moves down, smaller importers are catching up. Both patterns have implications for queue depth and total processing time.
- Protest processing data: We need separate statistics for protest-path claims to understand how that pipeline compares to PSC processing speed.
- Geographic distribution: Processing data by port of entry would help importers estimate their local wait times rather than relying on national averages.
- Staffing updates: Any changes to the 2,500-staff allocation or the supplemental budget request status.
We’ll analyze the next report as soon as it’s released. Subscribe to our weekly briefing for timely coverage of all CBP releases.
These CBP numbers make your specific situation more concrete. The Impact Assessment translates these system-wide statistics into projections for your portfolio — your entries, your queue position, your timeline. Request yours today and replace general estimates with specific, entry-level analysis. The data is clear: earlier action means earlier payment.
