Tariff refunds for liquidated entries open October 6, but only for importers with valid IOR numbers

The details

The terms come from a court filing by Brandon Lord, executive director of CBP’s Trade Programs Directorate, reported by Supply Chain Dive on September 17. Key mechanics:

• Who can file from Oct. 6: businesses that submitted a valid importer of record number to CBP by the end of July, for finally liquidated entries that were subject to tariffs enacted under the International Emergency Economic Powers Act and invalidated by the Supreme Court in February.
• Who must wait: claims for entries submitted after July 30, 2026 have no instructions or timeframe yet.
• What phase three covers: roughly $11.4 billion, or 6.9% of IEEPA tariffs. CBP had targeted end of July for this phase and delayed it; phases one and two launched earlier this year but did not handle finally liquidated entries.
• Where the money stands: as of September 11, CAPE (the Consolidated Administration and Processing of Entries portal) had accepted about $134.7 billion in potential and certified refunds, with $122 billion sent to Treasury for disbursement. Actual payouts were still running behind: $22 million paid as of September 11, according to CBP.
• The litigation caveat: the Justice Department has appealed a lower-court ruling that was expanded to include finally liquidated entries, arguing the refund order covers only parties that sued. Baker Tilly’s Pete Mento urged companies to check eligibility, including litigation status, before treating a refund as banked.

Note the interaction with a separate CBP rule: from September 18, an inaccurate Form 5106 can get an importer number voided outright (our coverage). A voided number is exactly what stands between an entry and a refund.

What buyers should do

• Confirm your IOR validity. Verify that a valid importer of record number was submitted to CBP by the end of July, and that Form 5106 data will survive the new accuracy enforcement.
• List your finally liquidated IEEPA entries with your broker, and file through CAPE when the window opens October 6.
• Check litigation posture before booking expected refunds; DOJ’s appeal means some liquidated entries may be claimable only by parties to the suits.
• Don’t spend it yet. With $122B approved but only $22M paid as of September 11, treat refunds as a receivable with timing risk, not cash.
• Track the post-July 30 tranche for separate instructions before forecasting those recoveries.

The bigger picture

The refund pipeline helps explain the year’s whiplash: IEEPA duties that raised importers’ costs were struck down in February, and CBP has been building the repayment plumbing in phases ever since. Where the money goes once it lands is its own procurement story — we looked at how companies such as Levi’s ($80 million) are reinvesting refunds in our report. For now, the practical lesson is that customs compliance data, litigation status and cash forecasting are the same project, and finance and procurement should run it together.