On April 20, 2026, CBP opened the CAPE portal, the exclusive system for recovering duties paid under IEEPA tariffs invalidated by the Supreme Court on February 20, 2026. The government owes approximately $166 billion to more than 330,000 importing businesses. Refunds are not automatic. Every importer must actively file. Most have not.
As of April 9, 2026, only 56,497 importers had completed the basic ACH enrollment required to receive payment. These 56,497 represent an estimated $127 billion of the pool and are largely enterprise importers with internal trade teams or existing customs broker relationships managing the process.
The remaining 273,500 importers share an estimated $39 billion in refunds and have not completed even the first step. Their average refund is approximately $142,000. They are small to mid-market businesses without dedicated trade compliance staff. They are searchable, identifiable, and reachable through the data sources documented in this report.
A customs broker earning 2 to 5% on recovered refunds needs to convert a single mid-market client from this list to recover the cost of this report many times over. A trade law firm billing on Phase 2 complex entries needs one engagement.
Only duties assessed under IEEPA authority between February 4, 2025 and February 24, 2026 are eligible. The following tariff categories are included in the CAPE refund pool.