Wednesday Environment Scan: $136 Billion in Tariff Refunds Is Moving. Is Your Company Collecting?

Wednesday, October 14, 2026 | Operations & Leadership Perspectives

Last Wednesday we scanned tariffs, AI and PMI signals.

This week, one signal deserves the whole scan: tariff refunds.

About $136.6 billion in potential and certified refunds is now moving through U.S. Customs, according to the National Law Review.

The money is real. It is not automatic. And it does not reach the companies that wait.

What Happened

On February 20, 2026, the Supreme Court held in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) “does not confer authority to impose tariffs” (Skadden).

That made the IEEPA duties importers paid eligible for refund.

U.S. Customs and Border Protection (CBP) built a refund process called CAPE (Consolidated Administration and Processing of Entries) inside its ACE system. Phase 1 opened on April 20, 2026 (FreightRight).

Three facts matter most for leaders:

• Refunds are not automatic. The importer of record, or its broker, has to file a declaration.
• No bank details, no refund. Importers must complete CBP’s ACH refund registration, or their refunds will be rejected.
• Timing rules decide eligibility. Entry status and liquidation dates determine which path applies, and some windows are short.

The Numbers This Week

As of October 2, CBP reported (National Law Review):

• 297,887 declarations received; 209,262 passed validation.
• Those cover 27.4 million entries and about $136.6 billion in potential and certified refunds.
• 6.2 million entries failed validation.

The failures came from three causes: entries outside CBP’s 90-day reliquidation window, entries missing the Chapter 99 tariff codes tied to IEEPA duties, and duplicate declarations.

Phase 3 opened October 6 for finally liquidated entries of importers that sued and won court-ordered reliquidation. So far 477 declarations covering 425,517 entries have been accepted (National Law Review).

The Court of International Trade also certified a nationwide class in the lead refund case. A Justice Department appeal is expected.

Where Money Is Being Left Behind

The Cato Institute estimated about $166 billion in IEEPA duties were collected. As of June 29, $104.29 billion had been authorized and $71.06 billion paid, including interest.

The gaps are telling:

• Missing bank details. Refunds for 8,384 approved declarations went unpaid because ACH information was missing.
• Big companies first. Approved refunds covered about 30% of entries but nearly 60% of the dollars, which suggests large importers have collected most of the money so far.
• Entries outside the phases. Cato estimated about $25 billion is owed on entries not covered by Phases 1 to 3.
• Finally liquidated entries. For these, a lawsuit at the Court of International Trade remains the surest route. Attorneys quoted by FreightRight put some of these matters at roughly $10,000 to $15,000.

In short, the refund goes to the organization that treats it like a project, not a form.

Which Path Applies

Sources: Skadden, National Law Review, FreightRight. Rules and windows are changing; confirm your situation with a licensed customs broker or trade attorney.

The Other Side of the Ledger: Tariff Costs Move Fast

New research from the Federal Reserve Bank of New York shows why this matters beyond the refund itself:

• About 90% of a tariff passes through to import prices, almost immediately.
• Retail import prices show half the effect within three months and all of it within six.
• Prices of U.S.-made goods take about a year to adjust.
• A one-point tariff increase raises consumer goods prices about 0.25% after a year.

Costs hit fast. Refunds come slowly and only to those who file. That gap sits in working capital.

What CFOs and COOs Should Do in the Next 30 Days

1. Assign one owner. Name a finance and trade lead accountable for the full refund, with a weekly review.
2. Pull the data. Get every IEEPA entry from ACE or your broker, with entry date, liquidation status, liquidation date and duty paid.
3. Register ACH now. Confirm CBP refund registration is complete and correct before anything else.
4. Sort by path. Group entries by phase and flag every protest and reliquidation deadline.
5. Fix failed declarations. Check for missing Chapter 99 codes, duplicates and timing errors, then refile where allowed.
6. Weigh legal action. For finally liquidated entries, compare litigation cost with the refund value.
7. Book it. Agree with your auditors how to recognize refunds and interest, and add expected cash to the 13-week forecast.
8. Talk to customers. If you passed tariffs through in price, decide your position before customers ask.

Questions for Your Leadership Team This Week

1. How much did we pay in IEEPA duties, and how much of it have we filed for?
2. Is our ACH refund registration with CBP complete?
3. Which of our entries failed validation, and why?
4. Who owns this recovery, and when do they report next?
5. If refunds arrive, where does the cash go: debt, inventory, pricing or investment?

The ENLOSA Perspective

At ENLOSA, we call this Stratactic™: Strategy + Execution.

The court decided the strategy question. What remains is execution: clean data, clear ownership, deadlines tracked, and cash brought home. Companies that run the refund like an operational project will recover more, faster.

Is This Happening in Your Organization?

If no one owns tariff refunds, entries are stuck in validation, or tariff costs are squeezing working capital, ENLOSA can help build the cross-functional process that turns a court ruling into cash.

Learn more about our Operational Value Creation approach.

ENLOSA: Global Business Solutions
enlosa@enlosa.com | +1 (877) 246-1109

This article is general information, not legal or customs advice. Consult a licensed customs broker or trade attorney about your entries.

Sources

• Skadden, “Tariff Refund Mechanism Takes Shape,” March 2026
• National Law Review, “Tariff-ied: This Week in International Trade,” October 12, 2026
• Cato Institute, “IEEPA Refunds Update: Good Progress, Still Ways to Go,” July 9, 2026
• FreightRight, “Months After IEEPA Tariffs Were Struck Down, Some Refunds Remain Caught Between Customs and the Courts,” September 17, 2026
• Amiti, Heise and Weinstein, “How Fast Do Tariffs Pass Through Into Consumer Prices?” Liberty Street Economics, Federal Reserve Bank of New York, October 6, 2026

#WednesdayEnvironmentScan #Tariffs #TariffRefunds #IEEPA #CustomsCompliance #SupplyChain #WorkingCapital #CFO #COO #Manufacturing #Strategy #OperationalValueCreation #Stratactic #EGBS

Visual photos via Unsplash: Desmond Charles Mushi, Vitaly Gariev, EqualStock.