$122 billion in tariff refunds has been certified. Is any of it yours?
CBP has processed more refund money than most shippers realize, and the next phase opens October 6, but only for importers who have already done the legal work.
After the Supreme Court struck down IEEPA tariffs in February, CBP built a system called CAPE to process refunds at scale. The numbers are large: roughly 330,000 importers paid an estimated $166 billion in IEEPA duties across more than 53 million entries. As of mid-September, CBP had accepted approximately $134.7 billion in potential and certified refunds, of which $122 billion, including interest, has been certified and transmitted to the Treasury for disbursement.
Phases 1 and 2 covered the straightforward cases, unliquidated entries, and certain reconciliation entries. Phase 3, deploying October 6, covers the harder ones: entries that have already gone through final liquidation, meaning they are past both the 314-day liquidation cycle and the 180-day protest window.
This is where most shippers need to pay attention, because Phase 3 is not an open door. Three conditions must all be met. The entry must have completed final liquidation. The filer must be a plaintiff in a pending case before the U.S. Court of International Trade seeking IEEPA refunds. The entry must fall within the scope of a court-ordered reliquidation. CBP has stated clearly that it does not have the authority to reopen finally liquidated entries on its own. There is no administrative workaround. No protest path. No exception.
Eligibility also depends on timing. Importers who submitted a valid importer of record number to CBP by July 30 can begin filing Phase 3 declarations on October 3. Those who missed that deadline are waiting on additional CBP guidance that has not yet been issued.
The action item is specific: confirm with your customs broker or trade counsel whether your IOR number was submitted, whether you are a plaintiff in a CIT case, and whether your finally liquidated entries are covered by a reliquidation order. If you paid IEEPA duties and have not taken those steps, October 6 does not help you yet, and the window to file suit and obtain a reliquidation order before Phase 3 launches is now measured in days. The CIT has been entering individual reliquidation orders within a week or two of filing, which means acting this week could still put you in position.
Per CBP’s September 15 court declaration filed by Brandon Lord, Executive Director of Trade Programs.
Your IOR number is now a liability if it is wrong
CBP began voiding importer of record numbers on September 18. A voided number stops cargo at the port with no advance warning.
This one connects directly to the CAPE story above. The same IOR number you need for IEEPA refunds is the one CBP is now actively scrubbing for accuracy, and the consequences of a bad record are immediate.
On August 19, CBP published a Federal Register notice announcing that it would begin voiding IOR numbers when the information on Form 5106 is inaccurate or incomplete. The language is direct: if CBP determines that an IOR or customs broker acting on behalf of an IOR has failed to provide complete and accurate information, CBP will void the IOR number, rendering it invalid for any purpose, including entering imported merchandise into the United States. Enforcement started September 18. There is no grace period.
The defects CBP is flagging are practices that many importers and brokers have treated as standard for years. The physical address on Form 5106 must be the actual location of the business. A registered agent’s address, a customs broker’s address, a freight forwarder’s address, a P.O. box, or a business services center address is now a defect. The email address and phone number must belong to the importer, not the broker or forwarder. CBP will send voiding notices to the email address on file, so if the email is wrong, the importer may not learn the number has been voided until a shipment stops moving.
This is not theoretical. CBP stated in the Federal Register notice that it is comprehensively reviewing Form 5106 data for all active importers of record.
The enforcement stems from Executive Order 14411, Strengthening Customs Enforcement, signed June 3, 2026. CBP is treating IOR identity verification as a front-line enforcement tool to prevent fraudulent origin declarations, undervaluation, and sanctions evasion.
What to do this week: pull your Form 5106 filing and confirm that the physical address, email, and phone number belong to your company, not your broker or forwarder. If anything needs correcting, file the update before CBP finds it first. And if you are pursuing IEEPA refunds through CAPE, verify that your IOR number is in good standing now, because a voided number will block your Phase 3 declaration.
Fuel surcharge update
Diesel pulled back from last week’s record, but fuel surcharges are still climbing faster than any other line on your invoice.
On-highway diesel averaged $6.382 per gallon for the week of September 28, down $0.147 from the $6.529 record set the prior week. One week of relief after three consecutive records does not change the trajectory. The year-to-date average is still closing in on the 2022 annual record of $4.989, and a single weekly dip does not reset carrier fuel surcharge tables fast enough to show up on your next invoice. Ground surcharges lag by a week; international air can take longer to reflect a decline than it took to absorb the increase.
This week’s UPS fuel surcharge table, effective September 28 and verified against UPS’s published 90-day history, tells the story clearly. International air import hit 48.75%, up a full point from 47.75% the prior week. International air export reached 46.00%. Domestic air is at 33.50%, domestic ground at 30.25%, and international ground at 30.75%. Every category rose week over week, and next Monday’s reset will reflect this week’s lower diesel, not the surcharge levels you are paying right now.
The 90-day view is worse. Domestic ground has climbed from 25.00% on July 6 to 30.25% today, a 5.25-point move in under three months. International air import has gone from 37.75% to 48.75% over the same stretch, an 11-point increase that most shippers have absorbed without a single contract amendment.
International fuel surcharges are the piece to watch. They track jet fuel, not the diesel index, and they are the surcharges most often left out of negotiated caps and discount structures. If your contract addresses domestic fuel but is silent on international, you are exposed to the fastest-moving cost on your invoice with no ceiling. At 48.75%, nearly half of every international air import shipment’s base charge is fuel surcharge alone.
The next EIA diesel print is October 6. UPS applies it the following Monday; FedEx the following Wednesday. If diesel holds near this level or dips further, ground surcharges should ease slightly the week of October 5, but the international air surcharge tracks jet fuel on a separate, faster-moving index.
What to watch
- September 29 – EIA weekly diesel release ($6.382, down from $6.529 record); U.S. bans select Canadian alcohol, dairy-related and motor-vehicle imports; 100% Section 232 tariff on patented pharmaceuticals and APIs takes effect for remaining companies
- October 1–7 – China Golden Week; factories close, export cargo front-loads the prior week; ocean and air bookings from China tighten
- October 3 – CAPE Phase 3 declarations open for importers who submitted IOR numbers by July 30
- October 4 – USPS 6% temporary holiday pricing begins (Priority Mail Express, Priority Mail, Ground Advantage, Parcel Select; runs through January 17)
- October 6 – CAPE Phase 3 deploys
- October 25 / 26 – UPS / FedEx residential demand surcharges begin
- November 22 – December 26/27 – Peak window; highest surcharge rates at all carriers
If you paid IEEPA duties, the refund window is open and widening, but only if your paperwork is in order. If you import anything, your IOR data is under review right now. You can check both this week, before the next round of deadlines arrives. Need help modeling the impact or identifying what you are owed? ICC Logistics is here to help you find the money before it moves past you.
