U.S. Customs and Border Protection has started processing refunds on finally liquidated entries hit by the defunct IEEPA tariffs — 477 declarations covering 425,517 entries were accepted as of Oct. 6, according to a court filing.

The payouts flow through CBP's Consolidated Administration and Processing of Entries portal, known as CAPE, Brandon Lord, executive director of CBP's Trade Programs Directorate, said in the Oct. 6 filing with the Court of International Trade.

There's a catch. Only plaintiffs who handed CBP a valid importer of record number by July 30, 2026 can currently get money back on finally liquidated entries. Anyone who submitted a number after that date must wait for further instructions, the filing says. CBP gave no timeline.

"Another important step in the CAPE process — and one importers involved in the tariff litigation will want to continue to monitor," Kelly Nelson, principal consultant and managing director of KPMG Trade & Customs Services, wrote on LinkedIn.

How big is the money?

Big — but this phase is a slice. The finally liquidated capability is expected to handle roughly $11.4 billion, or 6.9%, of IEEPA tariffs. The Supreme Court invalidated the duties, enacted under the International Emergency Economic Powers Act, in February.

The wider CAPE picture dwarfs that figure. As of Oct. 2, the portal had accepted about $136.6 billion in potential and certified refunds for processing, with $126 billion already sent to the Treasury Department for disbursement.

Why the delay?

CBP originally targeted the end of July for this third phase of the CAPE rollout. It slipped to October. The agency has not publicly detailed the reasons for the delay, and the filing simply marks the capability as live.

The timeline matters for cash flow. Importers carrying duty deposits on finalized entries have waited months for reimbursement, and litigation — not the portal — set the pace.

What does the appeal change?

Potentially everything. The CIT ruled earlier this year that CBP had to refund unprocessed or unfinalized entries, then expanded the order to cover finally liquidated entries as well. The Justice Department appealed, arguing the court lacks jurisdiction to issue a universal refund order for all finalized entries and that relief should reach only parties that actually sued.

That appeal remains live at the Federal Circuit Court of Appeals. A ruling there could narrow the universe of refund recipients — which is why importers with finally liquidated entries who have not yet joined the litigation may want to weigh their position with counsel.

What does this change for shippers?

For eligible plaintiffs, refunds are now mechanical: file through CAPE, confirm the importer of record number, and wait for Treasury disbursement. For everyone else, the July 30, 2026 cutoff is the operative line — miss it, and you're in the unspecified-instructions queue.

With $126 billion already moving to Treasury and the Federal Circuit appeal unresolved, the pace of payouts on finally liquidated entries will likely track the court's next ruling.