Source: Supply Chain Dive. Summary and analysis by S2V Advisory.
What happened
Supply Chain Dive reported that U.S. Customs and Border Protection will begin processing refunds on October 6, 2026, for finally liquidated entries that were subject to tariffs imposed under the International Emergency Economic Powers Act (IEEPA), which the Supreme Court invalidated in February 2026. Refunds are handled through CBP’s Consolidated Administration and Processing of Entries (CAPE) portal, and eligibility depends on importers having submitted a valid importer of record number by July 31, 2026.
According to the report, this third phase covers approximately $11.4 billion, or 6.9% of total IEEPA tariffs. As of September 11, CAPE had accepted $134.7 billion in potential and certified refunds, with $122 billion sent to the Treasury Department for disbursement. Some aspects of the ruling’s scope remain under appeal, so eligibility for specific entries can depend on the applicable court orders.
What it means for buyers
Tariff refunds are a procurement issue as much as a finance one, because many companies paid those tariffs indirectly through supplier price increases rather than as the importer of record. Buyers should make sure recovered value actually reaches the business:
- Map who paid. Separate goods you imported directly from goods where suppliers imported and passed tariff costs through as surcharges or price increases.
- Revisit supplier pricing. Where suppliers added tariff-related increases, ask how refunds they receive will be reflected in credits or future pricing, and document the answer.
- Coordinate with finance and your customs broker. Confirm filing status for your own entries and who owns follow-up on each refund stream.
- Tighten future contract language. Tariff pass-through clauses should specify how costs are evidenced and how refunds or reductions flow back to the buyer.
Refunds are a one-time recovery, but the discipline behind them lasts: knowing exactly what you paid, why, and whether it came back. See our Sustain service for value tracking that follows savings and recoveries through to the P&L.