For many importers, there's real money in that number worth paying attention to.
Here's the background:
Earlier this year, the Supreme Court ruled that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were illegal. CBP stood up a dedicated portal called CAPE to process refunds on the estimated $166 billion in duties collected under those tariffs. As of May 22, $20.6 billion has been certified and transmitted to Treasury for disbursement. Progress is being made, but the process has some meaningful gaps importers should understand.
What we're seeing in practice:
File-level rejections are more common than people expect. CBP requires submissions in a specific CSV format tied to its ACE system. Importer or filer mismatches, incorrect entry numbers, and formatting errors that don't conform to the published template are among the leading causes of rejection. These are fixable issues — but only if you catch them.
Some certified refunds aren't being disbursed. CBP flagged over 4,000 approved refunds that couldn't be sent to Treasury because ACH banking information was never provided. The refund was approved, but the payment details weren't on file. Worth checking if you're in that position.
Finally-liquidated entries are still in a holding pattern. CBP has acknowledged it's developing the capability to process these, but it isn't available yet. Importers with exposure in this category are waiting on a timeline outside their control.
Where outcomes differ:
Larger companies with dedicated compliance teams have been managing this process actively from the start. Mid-size importers with high entry volumes but leaner internal resources are more likely to have unreviewed rejections or missing documentation they're not yet aware of.
The practical takeaway is straightforward. This is a time-sensitive process with CBP's 90-day reliquidation authority is already excluding some entries from eligibility.
If you haven't reviewed your CAPE submissions, confirmed that your ACH details are on file, and checked whether any rejected entries can be corrected and resubmitted, now is a good time to do so.
Transmodal is happy to walk through what this looks like for your specific company if it would be helpful.