Update on IEEPA Tariff Refunds: CAPE Goes Live With Certain Limitations for Importers

In the days following the U.S. Court of International Trade’s (CIT) evolving orders directing U.S. Customs and Border Protection (CBP) to liquidate and reliquidate entries without International Emergency Economic Powers Act (IEEPA) tariffs, the refund landscape has materially changed. CBP’s automated refund tool went live on April 20, 2026, the universe of eligible entries has been narrowed by CBP, the Administration has signaled it will aggressively contest refunds, and a new lead case will... By: Snell & Wilmer