Trump administration readies refund system for struck-down tariffs on April 20

The Trump administration will open a refund system on April 20 for importers seeking repayment of tariffs the Supreme Court struck down in February, turning a sweeping trade defeat into a sprawling cleanup operation.

U.S. Customs and Border Protection says the first phase of the system, called CAPE, will run inside the Automated Commercial Environment Secure Data Portal and will be limited to certain unliquidated entries and certain entries within 80 days of liquidation. The agency says importers of record and authorized customs brokers must use an ACE Portal account and submit CAPE declarations by CSV file, with each filing able to contain as many as 9,999 entries. Once accepted, CBP says it will remove the IEEPA tariff line, recalculate duties and issue consolidated refunds by importer or designated party, including interest where applicable.

The money at stake is enormous. The tariffs in question add up to about $166 billion, and as of April 9, 56,497 importers had already completed the process to receive electronic refunds for affected duties totaling $127 billion. Reuters also reported that more than 330,000 importers paid the tariffs across 53 million shipments, showing how deeply the unlawful duties reached into U.S. supply chains. Government exposure has been estimated as high as $175 billion.

The refund machinery follows Learning Resources, Inc. v. Trump, decided by the Supreme Court on February 20, 2026. In a 6-3 ruling, the court held that the International Emergency Economic Powers Act does not authorize the president to impose tariffs. The decision covered tariffs Donald Trump imposed on Canada, Mexico and China, along with broader reciprocal tariffs on imports from other trading partners.

Lower courts then forced the issue into the refund queue. In March, the U.S. Court of International Trade ordered CBP to liquidate or reliquidate affected entries without the IEEPA duties in Atmus Filtration, Inc., and Judge Richard K. Eaton later said importers were entitled to refunds. CBP’s latest materials say approved refunds are expected to be paid electronically within about 60 to 90 days after a CAPE declaration is accepted, absent compliance concerns.

For businesses, the launch shows how far the gap can be between a trade announcement and a court-tested policy. Small-business groups that fought for repayment have pushed for automatic, fast refunds, while trade lawyers warn the phased rollout could still become slow, complicated and litigious. Even as CBP builds a path to repay unlawful duties, the administration continues pursuing new tariff measures under other authorities, leaving importers to sort through both the rollback and the next wave of trade risk.