This is the money importers paid under the tariffs the US Supreme Court ruled unlawful. In late February 2026 the Court held in Learning Resources v. United States that the duties imposed under the International Emergency Economic Powers Act, the IEEPA tariffs, were illegal. US Customs and Border Protection stopped collecting them on goods entered after 24 February 2026 and built a dedicated refund system, the Consolidated Administration and Processing of Entries, known as CAPE. In the first six weeks of CAPE Phase 1, CBP processed refunds on close to 8.5 million entries. We covered the legal fight over who qualifies in an earlier note on the refund eligibility ruling. This is the payout phase, and it comes with a trap.
The importer of record owns the refund
Only the importer of record, the IOR, can request a refund through the CAPE portal. A consumer cannot file. A buyer who was not the IOR on the entry cannot file. CBP pays the party named on the customs paperwork, and no one else.
You find that party in one place. On the CBP entry summary, form 7501, there is an importer of record box. If your company name and address sit in that box, you are the IOR, and the refund is yours to claim. If a courier's name sits there instead, the courier is the IOR, and the money runs back through the courier to you. The importer of record is the party that carries the customs liability on an entry, the same party CBP pursues when duties or penalties are owed. Now it is the party CBP pays.
That split matters because of how goods actually entered the US. On a full commercial container you booked yourself, your company was almost certainly the IOR. On smaller parcels shipped through an integrator, or on any shipment you bought on DDP terms where the seller or forwarder cleared customs for you, the courier or forwarder was often the IOR. Same goods, very different refund path.
What each path needs this week
If you were the IOR, the refund will not appear on its own. You, or your customs broker, file the claim through the CAPE portal against the specific entries. Pull your form 7501s for US entries between early 2025 and late February 2026, confirm your name is in the IOR box, and instruct your broker to file. Customs protests are deadline-driven, so stale entries can fall out of eligibility. This is not a wait-and-see task.
If a courier was the IOR, you do not file, and a filing would fail. The carrier reclaims from CBP and passes the money back to the party that originally paid the duty. FedEx says it will submit refund declarations for all customers for whom it acted as customs broker. UPS says it will request and retrieve refunds where UPS was the importer of record, then pay the original payor. DHL Express says it will automatically file for eligible Phase 1 entries. Your job there is narrow but real: make sure the carrier has you on record as the duty payer and that your billing and bank details are current, or the refund has nowhere to land.
Two cautions before you chase it
First, eligibility past the first phase is still contested. The US government has appealed the trade court order that extended refunds to all importers of record, so refunds move cleanly for entries CBP has already cleared while the broader question is litigated. Treat an approved refund as approved, and do not book money you have only assumed is coming.
Second, ignore anyone offering to recover your tariffs for a percentage. A class action and a wave of recovery-fee pitches are circulating around this payout. The only routes that work are your own CAPE filing as the IOR, or your existing courier or broker. No middleman is needed, and CBP does not pay one.
A US story, with a discipline that travels
This applies only to goods entered into the United States under IEEPA duties. If you import into the EU, the UK, or elsewhere, you have no IEEPA refund to claim. The principle underneath it travels, though. The party named as importer of record holds the customs relationship, carries the liability, and collects any money owed. If you cannot say who that party is on your own shipments, you are not in control of the entry.
That is the quiet cost of importing without a clear paper trail. The buyer who cannot name the IOR on last year's entries is usually the same buyer who cannot say which factory actually made the goods or which contract governs the next deposit. Mila keeps that trail in one place: the verified factory, the bilingual contract, the shipping documents, and the entry details, all visible in a single WhatsApp thread you watch and run. When a refund window like this one opens, you already hold the records to move on it.
Sources: Sourcing Journal / WWD, FedEx to return roughly $800 million in tariff refunds to customers from August (FedEx fiscal Q4 earnings, 24 June 2026). US Customs and Border Protection, IEEPA Duty Refunds and the CAPE program, with reporting that more than $95 billion has been approved or is set for approval and roughly $23 billion transferred to the Treasury for disbursement, and that CBP processed refunds on close to 8.5 million entries in the first six weeks of CAPE Phase 1 (Supply Chain Dive). Supreme Court of the United States, Learning Resources, Inc. v. United States, decided late February 2026 (IEEPA tariffs held unlawful). CBS News, how UPS, FedEx and DHL handle refunds and the importer-of-record requirement on form 7501. Holland & Knight, IEEPA tariff refund update on the government's appeal of the CIT refund order (June 2026).