The IEEPA tariff saga spans from February 4, 2025, when the first executive order imposed tariffs on China, through the Supreme Court’s 6-3 ruling in Learning Resources, Inc. v. Trump on February 20, 2026, and into the current CAPE system development period. Below is a complete chronological timeline of every significant event — see also our complete guide to IEEPA tariff refunds for the full recovery walkthrough. Last updated: March 25, 2026.
2025: Tariff imposition
February 4, 2025 — Executive Order 14195 (Fentanyl). President Trump signs EO imposing 10% IEEPA tariff on all imports from China, citing fentanyl trafficking. HTS code: 9903.01.20.
February 4, 2025 — Simultaneous EO imposes 25% IEEPA tariff on imports from Canada and Mexico under fentanyl rationale.
March 4, 2025 — China fentanyl rate increased from 10% to 20% cumulative. HTS code 9903.01.24.
April 2, 2025 — Executive Order 14257 (Reciprocal Tariffs). China’s cumulative IEEPA rate reaches 54%. HTS code: 9903.01.25. Reciprocal tariffs imposed on virtually every U.S. trading partner under HTS heading 9903.02.
April 9, 2025 — China’s reciprocal tariff increased to 125%. Cumulative rate reaches 145%. HTS code: 9903.01.63. This peak rate made China the highest-exposure origin country, which is why China-specific IEEPA analysis requires particular attention.
April 11, 2025 — Reciprocal tariff increases paused for most countries for 90 days. China excluded from the pause. China’s cumulative rate returns to approximately 54%.
July 8, 2025 — Pause expires. Reciprocal tariffs fully reimposed. China approximately 30-54% depending on product classification.
December 2025 — Earliest IEEPA entries (filed February 2025) begin liquidating. The 180-day protest window under 19 U.S.C. Section 1514 starts running on these entries.
2026: Ruling and recovery
The article's timeline shows why importers need both legal and operational awareness. Tariffs escalated in 2025, liquidation deadlines started before the ruling, and CAPE timing now sits on top of that older entry-level clock.
January 20, 2026 — CBP reports $155 billion collected under IEEPA authority since February 2025.
February 13, 2026 — Supreme Court grants certiorari in consolidated IEEPA tariff challenges.
February 20, 2026 — Supreme Court rules 6-3 that IEEPA tariffs are unconstitutional in Learning Resources, Inc. v. Trump. Chief Justice Roberts holds that IEEPA does not delegate tariff authority to the President. Estimated $166 billion in recoverable duties across 330,000+ importers. See our full ruling analysis.
February 24, 2026 — IEEPA tariffs officially suspended. CBP stops collecting IEEPA duties at ports of entry.
March 4, 2026 — CIT orders CBP to process refunds for all importers of record in Atmus Filtration, Inc. v. United States. Judge Eaton directs CBP to liquidate unliquidated entries without IEEPA duties and reliquidate entries where liquidation is not yet final. See our CIT order analysis.
March 6, 2026 — CIT order partially stayed while CBP builds the CAPE system. CBP reports 2,500 staff available to process 53 million entry lines.
March 11, 2026 — CBP begins CAPE development within the ACE platform. Target: 45-day build timeline.
March 19, 2026 — CBP files CAPE status update: Claim Portal 73% complete, Mass Processing 45% complete, Review and Liquidation 80% complete, Refund 63% complete. See our CAPE queue position analysis for implications.
Mid-April 2026 (projected) — CAPE portal launch target. CBP has stated claims will be processed in filing order.
Ongoing — 180-day protest deadlines running on earliest liquidated entries. First deadlines may expire as early as June 2026.
What the timeline means for your recovery
The timeline reveals three compounding urgency factors. First, protest deadlines are running on liquidated entries and the earliest windows close in approximately June 2026. Second, the CAPE portal launch is approaching, and CBP has confirmed first-in-first-out processing. Third, every day of delay erodes the time value of your refund.
Importers who understand their entry-level exposure now — which entries are unliquidated versus liquidated, which are within the protest window, and which are approaching deadline — can position themselves to file on day one of CAPE launch and preserve their protest rights simultaneously.
The practical implication is straightforward. Importers with entries from early 2025 face the tightest deadlines. Importers with entries from mid-to-late 2025 have more time but should not assume the CAPE system will resolve their claims before protest windows begin closing. A parallel strategy — filing protests on liquidated entries while preparing CAPE submissions for unliquidated entries — provides the broadest coverage. The four recovery paths analysis explains how each mechanism applies to different entry statuses.
Alternatives to waiting
Importers who cannot wait 18-36 months for CAPE processing can pursue immediate capital through claim assignment, which delivers non-recourse payment within 14-21 business days. The government filing vs. immediate capital comparison provides a decision framework.
Determine your position
Request a confidential Impact Assessment to map your specific entries against this timeline. The assessment identifies which deadlines apply to your portfolio and recommends the optimal recovery path for each entry. You can also use the eligibility screening tool for an initial qualification check, or review how our process works for a detailed walkthrough. Trade advisors who work with multiple importers may benefit from the partner referral program.
