Every Court Order Affecting IEEPA Tariff Refunds — Updated April 2026

Keeping track of every court ruling and CBP directive affecting IEEPA tariff refunds is a full-time job. New orders come down from the Court of International Trade, CBP issues implementation guidance, and the procedural landscape shifts week by week. If you’re an importer trying to understand where things stand, you need a single, current reference.

This tracker covers every significant legal and administrative development from the original Supreme Court ruling through April 2026. Each entry includes the date, the issuing body, what was ordered, and what it means for your refund. We update this page as new developments occur.

The Timeline at a Glance

February 20, 2026 — Supreme Court: Learning Resources, Inc. v. Trump

Ruling: The Supreme Court held 6-3 that IEEPA does not authorize the President to impose tariffs. All IEEPA tariffs imposed since February 2025 are unconstitutional and void from inception.

What it means: This is the foundational ruling. Every subsequent order builds on this decision. The ruling is final — there’s no appeal from the Supreme Court. The full case analysis breaks down the legal reasoning in detail.

For importers: Every dollar paid in IEEPA duties between February 4, 2025, and the date CBP stopped collecting is recoverable. The Supreme Court ruling overview covers the immediate practical implications.

February 24, 2026 — CBP Suspends IEEPA Collections

Action: CBP issued an operational directive removing all IEEPA tariff codes (HTS headings 9903.01 and 9903.02) from ACE. New imports are no longer assessed IEEPA duties.

What it means: The collection period is now definitively bounded: February 4, 2025, through February 24, 2026. Any duties collected during this window are subject to refund.

For importers: If you have entries in transit or pending liquidation that include IEEPA duty lines, those lines should be removed by CBP during processing. However, you should verify through your customs broker that this has occurred. Any entries that inadvertently liquidated with IEEPA duties after February 24 are subject to the same refund process.

March 4, 2026 — CIT Implementation Order (Atmus Filtration Technologies v. United States)

Order: The Court of International Trade, in Atmus Filtration Technologies v. United States, issued a comprehensive implementation order directing CBP to process refunds for all entries containing IEEPA duty lines. Key provisions include:

• CBP must establish an administrative process for universal refunds (no individual suit requirement)
• Refunds must include statutory interest under 19 U.S.C. Section 1505(c)
• CBP must report quarterly on processing progress
• The process must accommodate both unliquidated entries (via PSC or reliquidation) and liquidated entries (via protest or administrative correction)

What it means: This is the order that turned the Supreme Court’s constitutional ruling into a concrete administrative obligation. Without this order, importers would have been left to pursue refunds individually through protests and litigation. The CIT created a universal process.

For importers: The March 4 order analysis explains each provision in detail. The critical takeaway is that you don’t need to file a lawsuit to get your money back — but you do need to file through the administrative process CBP establishes.

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March 6, 2026 — Government Files Partial Stay Motion

Filing: The Department of Justice, on behalf of CBP, filed a motion requesting a partial stay of the March 4 order. The government argued that processing $166 billion in refunds simultaneously would strain CBP resources and create operational disruptions. The motion requested authority to phase refund processing over a longer timeline and to prioritize certain claim types.

What it means: This was the government’s attempt to slow down the refund process. The motion did not challenge the legal obligation to refund — only the timeline and sequencing.

For importers: The stay motion created temporary uncertainty about processing timelines. Importers who had been preparing to file immediately had to wait for the CIT’s ruling on the motion before knowing the exact process.

March 10, 2026 — CIT Denies Partial Stay

Order: The CIT denied the government’s partial stay motion, finding that (1) the constitutional obligation to return unlawfully collected duties is immediate, (2) CBP has existing systems capable of processing refunds, and (3) the potential harm to importers from further delay outweighs any administrative burden on CBP.

Key language: The Court noted that “the government’s interest in orderly administration does not override the constitutional right of importers to recover funds collected without legal authority” and directed CBP to proceed with implementing the March 4 order “without further delay.”

What it means: The refund process cannot be slow-walked. CBP must process refunds on the timeline established by the CIT, not on a timeline of the government’s choosing. This was a significant win for importers.

For importers: The denial removed the risk of a multi-year delay in even starting the refund process. It also increased the importance of filing position — with CBP unable to delay, the queue will move, and your place in it matters. See the CAPE queue position analysis.

March 14, 2026 — CBP Announces CAPE System

Announcement: CBP formally announced the Centralized Assessment and Processing Engine (CAPE) as the system that will handle all IEEPA refund claims. CAPE is designed to receive validated entry data, verify it against CBP’s records, calculate refund amounts including statutory interest, and authorize Treasury disbursements.

Key details:

• CAPE will accept filings from importers of record (directly or through customs brokers)
• Claims require validated entry-level data matching CBP’s ACE records
• Processing is sequential — first filed, first processed
• System launch projected for mid-April 2026

What it means: CAPE replaced the ad hoc process that many feared would result in inconsistent treatment across CBP ports. A centralized system means uniform processing rules and a clear queue.

For importers: Data preparation is now the critical path. Your customs broker needs to pull ES-003 reports, validate HTS codes, and ensure data completeness before CAPE launch. Our documentation guide covers the specific requirements. The cost of waiting explains why preparation before launch matters.

March 18, 2026 — CAPE Data Requirements Published

Publication: CBP released the technical specifications for CAPE submissions, including required data fields, validation rules, and file format requirements.

Required fields include:

• Importer of record number
• Entry number and entry summary number
• Entry date and liquidation date (if applicable)
• HTS classification codes (specifically 9903.01 and 9903.02 lines)
• IEEPA duty amount per entry line
• Port of entry
• Broker of record
• Preferred refund method (ACH or Treasury check)

Validation rules: CAPE will cross-reference submitted data against CBP’s ACE database. Discrepancies will result in the claim being flagged for manual review, which significantly delays processing.

What it means: Data accuracy is paramount. Claims with errors don’t get rejected outright — they get sent to a slower processing track.

For importers: Review your entry data now. Any discrepancies between your records and CBP’s records need to be resolved before filing. An Impact Assessment validates your data against known requirements.

March 21, 2026 — CIT Status Conference

Conference: The CIT held its first status conference to establish benchmarks for CBP’s compliance with the March 4 order. The Court set the following expectations:

• CAPE must be operational by mid-April 2026
• CBP must process a minimum of 5% of total claims per quarter
• Quarterly status reports must include claim counts, dollar amounts processed, and average processing times
• CBP must prioritize claims approaching 180-day protest deadlines to prevent importers from losing administrative remedies

What it means: The CIT is actively supervising CBP’s compliance. These aren’t suggestions — they’re benchmarks the Court will enforce. The 5% quarterly minimum means at least 16,500 importers processed per quarter (based on 330,000 total).

For importers: The deadline prioritization provision is important. If you have entries approaching the 180-day protest window, flagging this in your CAPE filing may result in accelerated processing. Your four recovery paths analysis should account for which entries need priority treatment.

March 28, 2026 — First CAPE Status Declaration

Filing: CBP submitted its first CAPE status declaration to the CIT, reporting on system development progress, staffing allocations, and projected processing capacity.

Key points:

• CAPE system development is on track for mid-April launch
• CBP has allocated approximately 800 staff to CAPE processing (out of 2,500 total)
• Projected initial capacity: 50,000 entry lines per week
• At projected capacity, full processing of 53 million entry lines would take approximately 20 months

What it means: The 20-month estimate aligns with the middle of the 18-36 month range that had been anticipated. However, initial capacity may increase as staff training progresses and system optimizations are implemented.

For importers: A 20-month processing window reinforces the value of early filing. The difference between being in the first month and the twentieth month is significant — both in time-value terms and in certainty. The time-value analysis quantifies what that delay costs you.

April 1, 2026 — CIT Compliance Review

Hearing: The CIT conducted its first formal compliance review, examining CBP’s progress against the March 4 order benchmarks. The Court found CBP in substantial compliance with preparations but raised concerns about:

• Staffing adequacy for the projected claim volume
• The manual review queue for claims with data discrepancies
• Communication protocols for importers whose claims are flagged

Orders issued:

• CBP must provide weekly (not just quarterly) updates on processing volume during the first 90 days of CAPE operation
• CBP must establish a dedicated communication channel for importers to check claim status
• The manual review queue must have its own processing timeline — claims cannot languish indefinitely

What it means: The CIT is tightening oversight. CBP has limited room to fall behind without judicial intervention. This is favorable for importers.

What’s Pending: April - June 2026

Several developments are expected in the near term:

CAPE System Launch (Mid-April 2026)

The CAPE system is expected to begin accepting claims. Importers who have validated data ready to submit will be in the earliest processing wave.

First Refund Disbursements (Late April - May 2026)

Based on CBP’s projected processing capacity, the first refund payments could be issued within 2-4 weeks of CAPE launch — for claims with clean data and no complications.

180-Day Protest Window Closures (June 2026+)

The earliest IEEPA entries (filed February 2025, liquidated approximately December 2025) may see their 180-day protest windows close as early as June 2026. Importers with entries approaching this deadline need to file protective protests now, regardless of CAPE status.

CIT Quarterly Benchmark Review (June 2026)

The CIT will evaluate whether CBP has met the 5% quarterly processing target established at the March 21 status conference. If CBP falls short, the Court may impose additional requirements or sanctions.

What to Watch For

As CAPE processing begins, several indicators will signal how the process is going:

1. Processing volume data — CBP’s weekly reports will show whether the 50,000 entry lines per week target is being met
2. Manual review queue growth — If a large percentage of claims are flagged, the effective timeline stretches
3. Congressional activity — Any appropriations bills that affect CBP staffing or CAPE funding
4. Further CIT orders — The Court may adjust benchmarks, impose new requirements, or address specific issues as they arise

We’ll update this tracker as each new development occurs. For a broader understanding of the legal framework, see the complete guide to IEEPA refunds.

Understanding the Legal Hierarchy

For importers trying to follow these developments, it helps to understand how the various courts and agencies relate to each other in the IEEPA refund context:

Supreme Court (Highest Authority)

The Supreme Court’s February 20 ruling is the foundation of everything. It established the constitutional principle that IEEPA doesn’t authorize tariffs. This ruling cannot be reversed by any lower court, by Congress (without a constitutional amendment), or by the executive branch. Every other order and directive flows from this ruling.

Court of International Trade (Implementation Authority)

The CIT is the specialized federal court that handles trade and customs disputes. Under 28 U.S.C. Section 1581, it has exclusive jurisdiction over cases arising under the tariff laws. In the IEEPA context, the CIT is the court directing CBP on how to implement the Supreme Court’s ruling. Its orders are binding on CBP and enforceable through contempt power.

The CIT’s March 4 order is the operational blueprint. It’s the order that transformed the Supreme Court’s abstract constitutional holding into a concrete administrative obligation with benchmarks and timelines.

CBP (Administrative Implementation)

CBP is the agency that actually processes refunds. It doesn’t make legal determinations — those come from the courts. CBP’s role is to execute the CIT’s orders: build the CAPE system, accept claims, validate data, calculate refunds, and authorize payments.

When CBP issues guidance or announces system specifications, it’s implementing court-ordered requirements, not exercising independent discretion. If CBP’s implementation falls short, the CIT has the authority to impose additional requirements.

Your Customs Broker (Your Interface)

Your customs broker is your operational connection to CBP. They file your claims, submit your data, and track your processing status through ACE. They don’t make legal or strategic decisions — that’s where your advisory team and your Impact Assessment come in. But they’re the hands-on-keyboard party that actually interacts with the government systems.

Reading the Orders: What to Focus On

When new orders are issued, here’s what matters most for your recovery:

1. Timeline requirements — Any new deadlines or processing benchmarks that affect when you’ll be paid
2. Data or procedural requirements — Changes to what CBP requires in your filing (additional fields, different formats, new validation rules)
3. Priority categories — Whether the court has directed CBP to prioritize certain types of claims (e.g., those approaching protest deadlines, small business importers, specific entry types)
4. Compliance findings — Whether the court has found CBP in compliance or non-compliance with prior orders, which signals how fast the process is actually moving
5. Interest rate determinations — Any orders addressing the calculation of statutory interest or the rate applicable to specific time periods

How This Affects Your Recovery Strategy

The legal and administrative timeline directly affects your recovery path decision. If CAPE processing moves faster than projected, the government path becomes more attractive. If delays emerge, the immediate capital option becomes relatively more valuable.

Your CFO’s analysis should be dynamic — updated as new orders and processing data become available. The one thing that doesn’t change is the importance of having your data ready and your claims filed. Queue position is determined by filing date, and that clock is already running.