The working-capital story manufacturers have been modeling since February is now showing up in liquidated entries. U.S. Customs and Border Protection has approved roughly $35.46 billion in refunds — including statutory interest — for tariffs imposed under the International Emergency Economic Powers Act and later struck down by the Supreme Court, according to figures CBP disclosed for the period through May 11, 2026 (CBS News). Of the 126,237 refund declarations filed through CBP's new Consolidated Administration and Processing of Entries (CAPE) tool, 86,874 have passed validation, covering more than 15.1 million entries; 8.3 million entries have already been liquidated or reliquidated without the IEEPA duties attached.
That is a fraction of what is still owed. Penn Wharton's Budget Model and industry estimates put the government's total IEEPA refund exposure at $166–175 billion, spread across more than 330,000 importers and roughly 53 million shipments (Penn Wharton Budget Model). For the manufacturers who stockpiled aggressively during the 2025 tariff layer, the question is no longer whether the cash is coming. It is how fast, how much, and what to do with it.
How we got here
On February 20, 2026, the Supreme Court ruled 6–3 in V.O.S. Selections Inc. v. United States that the IEEPA tariffs imposed beginning in April 2025 exceeded the President's statutory authority, with the majority also flagging Export Clause concerns around taxing imports under IEEPA's "regulate" power (SCOTUSblog). The ruling did not touch the Section 232 stack on steel, aluminum, autos, and derivative articles, nor the Section 301 duties on Chinese imports — both remain in force.
CBP's CAPE tool went live inside ACE at 8:00 a.m. EST on April 20, 2026. Phase 1 is narrow by design: it covers unliquidated entries and entries still within the roughly 90-day voluntary reliquidation window, with CSV declarations capped at 9,999 entries per batch (Holland & Knight). RSM and other practitioners are telling clients to expect cash to land roughly 60–90 days after CAPE acceptance, though processing realities have stretched that for many filers (RSM US).
The validation friction is real. Of the 126,237 declarations submitted through May 11, only about 69% — the 86,874 figure — have passed CBP's file checks. The rest are bouncing on formatting, HTS coding, or entry-status mismatches that brokers are working through in second and third submissions.
Who is collecting
The 2025 front-loading wave was not evenly distributed, and neither is the refund pool. The largest claim concentrations are sitting in goods categories that took the brunt of the April 2025 reciprocal tariff layer:
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Furniture, kitchen cabinets, vanities, and lumber — categories that were already facing a separate furniture and wood tariff schedule announced for later in 2025 (Supply Chain Dive) and where importers pulled forward aggressively.
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Consumer appliances, where GE's stockpiling through Q2–Q3 2025 was cited at the time as a competitive edge against Whirlpool — and is now translating into a refund advantage of the same shape.
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Chinese-source electronics components caught in the IEEPA layer above the surviving Section 301 base.
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Fasteners and derivative steel articles that were sitting in the IEEPA stack on top of Section 232 base duties — those derivative-article importers are receiving the IEEPA delta back while continuing to pay the 232 floor.
At the OEM level, the named examples are starting to show up in guidance. General Motors raised its full-year 2026 outlook citing roughly $500 million in expected tariff refunds (CFO Dive). Ford's Q1 2026 guidance hike also reflected refund recoveries, with the CFO publicly framing it as one input among several rather than the whole story (The Detroit News).
The interest math is more generous than people think
Refunds under CAPE accrue interest at CBP's overpayment rate under 19 CFR 24.36 — 7% for noncorporate filers and 6% for corporates for the quarter beginning January 1, 2026 — compounded daily from the date the duties were originally collected (CLA; rate schedule at IRS). For an importer that paid IEEPA duties in May 2025, that is roughly a year of daily-compounded interest on top of the principal.
That cushion does not make the wait free. The Cato Institute estimates that processing delays are costing claimants roughly $20 million per day in foregone yield differentials versus what the cash could be earning if it were already in hand (Cato at Liberty). For a mid-cap manufacturer waiting on a nine-figure claim, the gap between CBP's 6% and a working revolver drawn at 7%+ is a real number on the quarterly P&L.
What CFOs are doing with the cash
The deployment patterns emerging across earnings calls and practitioner notes are converging on a short list:
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Capex pull-forward into 2026 H2, particularly automation and capacity projects that had been deferred during the 2025 tariff-cost crunch.
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Revolver paydown — many of the firms that front-loaded inventory in 2025 did so on drawn credit lines, and the refund is the most efficient way to unwind that.
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Buyback and dividend authorizations at firms with cleaner balance sheets.
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Claim-sale exits for mid-cap filers that need cash now and would rather take a discount than wait out CBP. A secondary market has emerged in which hedge funds and specialty financiers buy IEEPA refund claims outright, providing immediate liquidity at a haircut (CBIZ). Sidley Austin's practitioner guidance walks lenders, borrowers, and claim purchasers through the structuring — including how refund claims interact with existing credit agreements and collateral packages (Sidley Austin).
What did not get refunded
The IEEPA refund is not a clean tariff reset. Three pieces of the rate stack are still live or contested:
Section 232 duties on steel, aluminum, autos, and derivative articles are unaffected by the SCOTUS ruling. Section 301 duties on Chinese imports likewise remain fully in force. Manufacturers in those categories are getting the IEEPA delta back, not the full landed-cost relief many initial press accounts implied.
The administration's 10% Section 122 "balance-of-payments" surcharge — which took effect February 24, 2026 as a partial replacement for the lost IEEPA revenue, statutorily limited to 150 days and scheduled to expire July 24, 2026 (White & Case) — was struck down by the Court of International Trade on May 7, 2026. The CIT held the White House had cited a trade deficit rather than the balance-of-payments deficit the statute actually requires (Holland & Knight). The ruling is under appeal, and importers paying Section 122 duties in the interim should keep protective protests live (Greenberg Traurig).
The capex window may close faster than the refund cycle
Treasury Secretary Bessent has publicly stated that the combined Section 122, 232, and 301 measures would leave 2026 tariff revenue "virtually unchanged" from IEEPA-era levels. In plain English: the administration is rebuilding the rate stack through surviving authorities. For manufacturers modeling a multi-year cost benefit from the SCOTUS ruling, that signal matters. The IEEPA refund is a one-time working-capital event. The forward rate environment is being reconstructed through 232 expansions, ongoing 301 maintenance, and whatever survives the Section 122 appeal.
That argues for treating the refund as exactly what it is — a balance-sheet event, not a margin tailwind — and for pulling capex decisions forward before the 2027 rate picture settles.
A practical checklist for manufacturing CFOs
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Confirm broker filing status. Ask your customs broker for the count of CAPE declarations submitted on your behalf, the number that have passed validation, and the entry totals on each. The 31% validation-failure rate is industry-wide, not idiosyncratic — but you need to know whether your share is sitting in the bounced pile.
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Track Phase 1 scope carefully. Phase 1 covers unliquidated entries and entries within the 90-day reliquidation window. Anything outside that scope needs to wait for later phases or be preserved through protests; CBP's official refund instructions are summarized by Norton Rose Fulbright and CBP's own page (CBP).
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Model the interest accrual into Q3 forecasts. Daily-compounded 6% on a corporate refund accruing from May 2025 collection is a non-trivial line on the income side of the refund check.
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Price the claim-sale option. If your treasury team can deploy the cash at a return above the discount being offered by the secondary market, sell. If not, wait. Either way, get the quote.
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Keep Section 122 protests alive. The CIT ruling is on appeal; protective filings preserve refund rights if the appellate court affirms.
The $35.46 billion CBP has already approved is the visible part of the windfall. The remaining $130-plus billion is the part that will define second-half 2026 balance sheets — and the manufacturers who treated 2025 inventory as a calculated bet on legal uncertainty are about to find out what the bet paid.
Related reading
Sources
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Businesses starting to receive their IEEPA tariff refunds — CBS News
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Supreme Court Tariff Ruling: IEEPA Revenue and Potential Refunds — Penn Wharton Budget Model
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CBP issues tariff refund instructions — Norton Rose Fulbright
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Trump Administration Imposes 10% Section 122 Tariff — White & Case
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US Tariff Update: Section 122 Duties Found Unauthorized by Law — Greenberg Traurig
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GM raises guidance on $500M tariff refund expectation — CFO Dive
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Ford's guidance hike reflects more than tariff refund — The Detroit News
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Tariff Refund Delays Could Cost Taxpayers $700 Million a Month — Cato at Liberty
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Hedge Funds Capitalize on Tariff Refund Opportunities — CBIZ
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IEEPA Tariff Refund Claims: Key Considerations — Sidley Austin
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US to begin furniture, wood import tariffs on Oct. 14 — Supply Chain Dive