CAPE Refund Pipeline Tops $100 Billion Sent to Treasury

CBP’s CAPE refund program has crossed a major milestone. The agency’s August 4, 2026 progress declaration reports that approximately $100 billion in IEEPA refunds has been completed and sent to the U.S. Treasury for disbursement as of July 31, 2026 — up from $86.3 billion as of July 10. Total potential and certified refunds accepted for processing reached approximately $128.68 billion. If you paid IEEPA tariffs between February 2025 and February 2026, get a free assessment to see where your refund stands in this pipeline.

What the $100 Billion Milestone Means

The $100 billion figure is the strongest signal yet that the CAPE system is the workhorse for IEEPA refunds — not just a pilot. CBP has now certified and transmitted more than $100 billion in refunds (duties plus interest) to Treasury for disbursement, and Treasury’s accounting system confirms the certified refunds are being regularly dispersed.

But a large pipeline is not the same as every importer getting paid. Two gaps stand out in the August 4 report, and both are actionable for you:

1. ACH information is missing for 19,726 refunds (about $1.6 billion). This is roughly double the 9,837 held refunds reported on July 10. If you have not verified ACH refund banking in ACE, your approved refund can sit at the disbursement step. See our ACH enrollment guide.
2. 5.02 million entries failed entry-level validation. The most common reasons are entries past CBP’s 90-day reliquidation authority, entries without a Chapter 99 IEEPA HTS line, and entries already filed on a prior CAPE declaration. See our validation error guide.

The Numbers Behind the Report

CBP Executive Director Brandon Lord’s declaration reports the following as of 3:00 p.m. EDT on July 31, 2026:

The most common file-validation failures remain importer-of-record or filer mismatches, entry-number problems, and CSV files that do not match the published template. The 7-step CAPE guide walks through each validation check.

ACH Backlog Doubles: 19,726 Refunds Await Banking Information

The sharp jump in ACH-blocked refunds is the single most important caution in the August 4 report. In about three weeks, the number of refunds held because importers have not provided ACH account information went from 9,837 (as of July 10) to 19,726 refunds totaling approximately $1.6 billion (as of July 31).

Missing ACH information is not a CAPE rejection — it is a disbursement hold. The refund may be fully processed and certified, but it will not be transmitted to Treasury until the importer of record (or its authorized CBP Form 4811 designee) has valid ACH refund banking on file in ACE. The Court of International Trade again urged CAPE declaration filers to make sure ACH information has been provided.

Check yours now: log in to ACE, open the Importer Account view, and confirm the ACH Refund Authorization tab has valid banking information for whoever will receive the refund. See our ACE account setup guide if you are not sure where to look.

The Reliquidation Order Has Now Been Entered

The August 5, 2026 CIT order confirms that Judge Eaton’s July 17 reliquidation order has now been entered in more than 3,700 IEEPA cases. That order directs CBP to reliquidate, without regard to IEEPA duties, all entries liquidated for more than 80 days on which plaintiffs made estimated IEEPA deposits — including finally liquidated entries that CAPE previously could not touch.

Two boundaries matter:

• It applies only to plaintiffs in the court-assigned cases, who must submit importer-of-record identification numbers to CBP. Importers who did not file a CIT lawsuit are not covered.
• It is not a general Phase 3 launch. No public Phase 3 filing lane has been announced. For non-litigant importers, the Freestyle World class-certification motion remains the principal open question, with oral argument set for August 19.

Read the full reliquidation order analysis and the finally liquidated CIT path guide for the plaintiffs-vs-non-litigants decision framework.

What’s Next: August 19 Hearing, August 25 Report

The August 5 order set the next official CAPE checkpoints:

• August 14 — Freestyle World plaintiff reply on class certification
• August 17 — closed pre-oral argument conference (Freestyle World)
• August 19 — oral argument on the Freestyle World class-certification motion, 11:00 a.m. EDT, Courtroom 1, One Federal Plaza, New York
• August 25 — CBP’s next CAPE progress report due by 5:00 p.m. EDT
• August 26 — closed settlement conference, 2:00 p.m. EDT, in person and via Webex

Track every checkpoint on the CAPE Update Tracker and in the full timeline.

What Importers Should Do Now

1. Verify ACH information today. With 19,726 refunds held for missing ACH, this is the single highest-leverage fix. Confirm the ACH Refund Authorization tab in ACE for the actual refund recipient. See the ACH enrollment guide.
2. File Phase 1 and Phase 2-eligible entries now. Phase 3 is not live. Clean unliquidated entries and reconciliation-flagged entries (Entry Types 01, 02, 06 without a Type 09 on file) remain the fastest path to refund. See the 7-step guide.
3. Protect protest deadlines. The 180-day protest window runs independently of CAPE. File protective protests on entries still inside the window. See the protest filing guide.
4. Get counsel review for finally liquidated entries. If you are a plaintiff in a court-assigned case, watch for CBP’s instructions to counsel and prepare your IOR identification numbers. If you are a non-litigant with material finally liquidated exposure, ask trade counsel whether an individual 28 USC 1581(i) complaint is appropriate. Request a free assessment and we will connect you with vetted trade counsel.

The CAPE pipeline has passed $100 billion, but your refund still depends on your ACH setup and entry posture. Get a free assessment and a vetted trade-law professional will review your refund status and recommend next steps.

Source Notes

Sources: CBP Executive Director Brandon Lord, Declaration, August 4, 2026 (ECF No. 24); CIT, Freestyle World, Inc. v. United States, Court No. 26-01088, August 5, 2026 order (ECF No. 25); CIT, July 17, 2026 reliquidation order (ECF No. 52). CAPE Portal Guide is not a law firm, customs broker, or government agency.