Refunds are moving. U.S. Customs and Border Protection has begun paying back tariffs collected under the International Emergency Economic Powers Act (IEEPA) for entries that have reached what trade compliance specialists call "finally liquidated" status.

Supply Chain Dive reported the development this week. The dollar value of refunds already issued, the number of importers affected, and the average payment size were not disclosed in the report.

What "finally liquidated" actually means

Customs liquidation is the agency's final calculation of duty owed on a specific import entry. Once an entry is liquidated, an importer has a defined window — set by U.S. customs law, generally 180 days — to file a protest challenging the duty assessment.

Entries that have cleared that window, and any subsequent litigation, are "finally liquidated." Only then can CBP legally return the duty.

That timing distinction explains why most importers have not yet seen a refund. The bulk of IEEPA-duty entries from the imposition period remain inside, or only recently outside, the protest clock. The pool of eligible entries expands daily as more protests age out.

What the report leaves out

The Supply Chain Dive headline confirms the pipeline is open. The story does not specify:

• how much money has moved so far
• how many entries or importers have been processed
• whether refunds are flowing by check, ACH transfer, or as credits against future duty bills
• whether processing is running on a first-in, first-out queue or sorted by entry type

CBP has historically declined to publish running refund totals, so brokers and importers should not expect a public dashboard any time soon.

Commercial fallout by desk

Importers: cash tied up in contested IEEPA duties can return to working capital. The benefit lands hardest on mid-sized operators that fronted duties on hundreds of containers and carried the cost on their balance sheets through the imposition period.

Customs brokers: new administrative work follows every refund. Brokers must reconcile the original payment against the returned duty, log it in CBP's ACE portal, and update accounting entries for clients — none of it optional, all of it unbillable at scale.

Ocean carriers and freight forwarders: landed-cost math on lanes that priced IEEPA duties into 2025 contract bids may need revision. China-origin flows led the volume exposure; certain Mexico- and Canada-origin traffic added meaningful tonnage.

The caveats behind the headline

Two. First, refunds only flow for entries that have cleared every legal hurdle. Entries still under active protest, or in litigation, stay on hold until those proceedings resolve.

Second, IEEPA itself remains under judicial review, including at the Supreme Court. Refunds now flowing cover duties that the government has conceded or that lower courts have struck down on a case-by-case basis. A broader ruling against IEEPA authority would expand and accelerate refunds; a narrow ruling could leave most contested duty in importers' hands permanently.

A third caveat, often unstated: an importer that receives a refund and then later has a protest reinstated under a narrower ruling could face a call for repayment. That risk argues for keeping refund proceeds segregated, not folded into operating cash, until the litigation landscape stabilizes.

What brokers and importers should do now

Pull the entry list. Confirm which entries have liquidated and aged past the protest window. File or close outstanding protests on entries the importer intends to challenge; let the clock run on entries it does not. Reconcile ACE duty records against the importer's general ledger before any refund arrives, so the cash is matched to the right entry from day one.

The bottom line

CBP has switched on the refund pipeline for finalized IEEPA entries. The pipeline's throughput depends on how many entries clear the protest clock each week — a number that grows daily but that neither the agency nor the trade press is currently publishing. For importers, the practical gate is the protest window on each individual entry; that is what determines when working capital comes back to the balance sheet.