IEEPA Tariff Refund Deadline: Up to $175 Billion Available, But the Clock Is Closing Per Entry

The Supreme Court struck down IEEPA tariffs 6-3 on February 20, and all IEEPA duties terminated February 24. The refund is real, CBP's CAPE system launched Phase 1 in April and Phase 2 in June, with industry estimates placing the refund pool at up to $175 billion. A federal judge ordered reliquidation on July 17 after the government argued it couldn't refund finally-liquidated entries; the government immediately appealed, so this remains live litigation.

The window is rolling: 80 days per entry, and those clocks are expiring now. Most lean customs teams have not been auditing this systematically.

The IEEPA tariff refund deadline risk is highest for manufacturers who shifted sourcing to Vietnam or Southeast Asia during the 2025 tariff surge, those same origins may now be inside the new 12.5 percent Section 301 duty net that took effect July 24. The administration bridged from IEEPA to Section 122 authority, never previously invoked, and then to new Section 301 investigations, landing a two-tier 10 and 12.5 percent duty regime with zero congressional votes. The sunk-cost restructuring made to escape one regime may have landed you inside the next one.

The Manufacturers Alliance data reframes this for Indiana fabricators: the "significant negative impact" score for fabricated metal dropped from 27 percent to 6 percent as IEEPA fell, but primary metal producers went from zero to 20 percent as cheaper foreign supply re-entered. Buyers and sellers of steel and aluminum are now on opposite sides of this repricing.

Action: Get your customs team auditing IEEPA duty entries from February 4, 2025 through February 24, 2026. Identify which entries are still inside the 80-day CAPE protest window and quantify what is recoverable before those clocks run out.