🟢 Phase 3 Ordered Reliquidation ordered for CIT plaintiffs July 17 — the CAPE Phase 3 portal function is not yet live — $128.68B accepted, ~$100B sent to Treasury
WIRE 💰 AUG 4 CBP FILING: $128.68B accepted for processing in CAPE — approximately $100B in duties plus interest certified and sent to Treasury for disbursement (Lord Decl., data as of 3pm ET July 31)◆ ⚠️ STUCK REFUNDS DOUBLED: 19,726 refunds totaling ~$1.6B have NOT been transmitted to Treasury — no ACH account information from the importer of record or its Form 4811 designee. That was 9,837 a month ago◆ 🔴 CAPE PHASE 3 PORTAL FUNCTION IS NOT LIVE — CBP's August 4 report describes no Phase 3 deployment, and CBP's July 23 notice still lists entries for which liquidation is final as NOT accepted on a CAPE Declaration◆ ⚖️ JULY 17 CIT ORDER: Judge Eaton ordered CBP to reliquidate finally liquidated entries — a case-linked path for the ~3,700 filed CIT plaintiffs only, with counsel supplying importer IDs◆ 📍 SECTION 338 CANADA — FIVE DAYS OUT: 50% additional duties take effect 12:01 AM ET August 19 on three sets of Canadian goods. No USMCA carve-out. No expiration date◆ ⚑ FTZ TRAP: covered Canadian goods admitted to a foreign trade zone on or after Aug 19 must enter under privileged foreign status (19 C.F.R. 146.41) — otherwise they pick up the 50% on consumption entry◆ 📊 CAPE VOLUME as of July 31: 252,496 declarations submitted • 178,213 passed file validation • 25.1M entries accepted for IEEPA duty removal • 17.69M since liquidated or reliquidated without IEEPA duties◆ ❌ 5.02M entries FAILED entry-level validation — primary reasons: entry date past CBP's 90-day reliquidation authority, no Chapter 99 HTS number used to assess IEEPA duties, or the entry was already on a prior CAPE declaration◆ ✅ JULY 28: Fed. Cir. dismissed Appeal No. 2026-1898 (Euro-Notions) on the government's own motion — Nos. 2026-1895 (lead), -1897, -1899 remain consolidated and active◆ 📅 DOJ's Federal Circuit opening brief was due August 3, 2026 — not confirmed filed on the docket as of August 14, 2026◆ 📌 Judge Eaton designated Freestyle World, Inc. v. United States (1:26-cv-01088) as the lead IEEPA refund case — oral argument ordered for August 19◆ ⚠️ JULY 24: Section 122 expired — replaced same-day by new Section 301 forced-labor tariffs (10–12.5%) on 60 countries. Goods already subject to Section 232 are EXEMPT from the new 301◆ 📈 Don't assume the announced rate is what you paid — rates shifted repeatedly across the IEEPA period. Pull ACE report ES-003 for your actual duties assessed before estimating a refund◆ ⚖️ Liberty Justice Center is fighting on two fronts: a CIT class certification motion for importers stuck outside CAPE, and a separate challenge to the new Section 301 forced-labor tariffs◆ 📅 Class certification motion (Rule 23(b)(2), V.O.S./Terry Precision) filed June 4, 2026 — class defined by CURRENT CAPE ineligibility, not final liquidation alone◆ 🔄 Reconciliation deadline within 30 days? File Type 09 first per CBP guidance — 2.2M reconciliation-flagged entries are already filed in CAPE and set for processing◆ ⚔️ 90-day §1501 statutory liquidation-finality window vs. 80-day practical CAPE cutoff — these are not the same date, ask which one applies to you◆ ⚖️ SCOTUS 6-3 Feb 20: Learning Resources v. Trump — IEEPA tariffs ruled unlawful • $166B+ refundable across ~53M entries and ~330,000 importers of record (CIT court filings)◆ WIRE 💰 AUG 4 CBP FILING: $128.68B accepted for processing in CAPE — approximately $100B in duties plus interest certified and sent to Treasury for disbursement (Lord Decl., data as of 3pm ET July 31)◆ ⚠️ STUCK REFUNDS DOUBLED: 19,726 refunds totaling ~$1.6B have NOT been transmitted to Treasury — no ACH account information from the importer of record or its Form 4811 designee. That was 9,837 a month ago◆ 🔴 CAPE PHASE 3 PORTAL FUNCTION IS NOT LIVE — CBP's August 4 report describes no Phase 3 deployment, and CBP's July 23 notice still lists entries for which liquidation is final as NOT accepted on a CAPE Declaration◆ ⚖️ JULY 17 CIT ORDER: Judge Eaton ordered CBP to reliquidate finally liquidated entries — a case-linked path for the ~3,700 filed CIT plaintiffs only, with counsel supplying importer IDs◆ 📍 SECTION 338 CANADA — FIVE DAYS OUT: 50% additional duties take effect 12:01 AM ET August 19 on three sets of Canadian goods. No USMCA carve-out. No expiration date◆ ⚑ FTZ TRAP: covered Canadian goods admitted to a foreign trade zone on or after Aug 19 must enter under privileged foreign status (19 C.F.R. 146.41) — otherwise they pick up the 50% on consumption entry◆ 📊 CAPE VOLUME as of July 31: 252,496 declarations submitted • 178,213 passed file validation • 25.1M entries accepted for IEEPA duty removal • 17.69M since liquidated or reliquidated without IEEPA duties◆ ❌ 5.02M entries FAILED entry-level validation — primary reasons: entry date past CBP's 90-day reliquidation authority, no Chapter 99 HTS number used to assess IEEPA duties, or the entry was already on a prior CAPE declaration◆ ✅ JULY 28: Fed. Cir. dismissed Appeal No. 2026-1898 (Euro-Notions) on the government's own motion — Nos. 2026-1895 (lead), -1897, -1899 remain consolidated and active◆ 📅 DOJ's Federal Circuit opening brief was due August 3, 2026 — not confirmed filed on the docket as of August 14, 2026◆ 📌 Judge Eaton designated Freestyle World, Inc. v. United States (1:26-cv-01088) as the lead IEEPA refund case — oral argument ordered for August 19◆ ⚠️ JULY 24: Section 122 expired — replaced same-day by new Section 301 forced-labor tariffs (10–12.5%) on 60 countries. Goods already subject to Section 232 are EXEMPT from the new 301◆ 📈 Don't assume the announced rate is what you paid — rates shifted repeatedly across the IEEPA period. Pull ACE report ES-003 for your actual duties assessed before estimating a refund◆ ⚖️ Liberty Justice Center is fighting on two fronts: a CIT class certification motion for importers stuck outside CAPE, and a separate challenge to the new Section 301 forced-labor tariffs◆ 📅 Class certification motion (Rule 23(b)(2), V.O.S./Terry Precision) filed June 4, 2026 — class defined by CURRENT CAPE ineligibility, not final liquidation alone◆ 🔄 Reconciliation deadline within 30 days? File Type 09 first per CBP guidance — 2.2M reconciliation-flagged entries are already filed in CAPE and set for processing◆ ⚔️ 90-day §1501 statutory liquidation-finality window vs. 80-day practical CAPE cutoff — these are not the same date, ask which one applies to you◆ ⚖️ SCOTUS 6-3 Feb 20: Learning Resources v. Trump — IEEPA tariffs ruled unlawful • $166B+ refundable across ~53M entries and ~330,000 importers of record (CIT court filings)◆
🟢 Ordered July 17 — Portal Not Yet Open
Reliquidation Ordered for Filed CIT Plaintiffs — Not a Public Phase 3 Launch Judge Eaton ordered CBP to reliquidate finally liquidated entries for the ~3,700 companies with filed CIT cases. CBP's August 4 report describes no Phase 3 deployment, and finally liquidated entries still aren't accepted on a CAPE Declaration.
🔴 Section 338 Canada — 5 Days Out
50% Canada Duties Effective 12:01 AM ET Aug 19 — No USMCA Carve-Out Three July 20 proclamations, no expiration date, stacking on other duties. Goods entering an FTZ on or after Aug 19 must be in privileged foreign status or they pick up the 50% anyway.
⚠️ Stuck Refunds Doubled
19,726 Certified Refunds Worth ~$1.6B Are Sitting Unpaid They can't be transmitted to Treasury because no ACH information was provided. That count was 9,837 a month ago. Enroll ACH in the ACE Portal before your refund certifies, not after.
Phase 3 Ordered • Portal Not Yet Live • CIT Filing Still Decides Coverage

Phase 3 Is Ordered.
The Portal Isn't Open.
Filing at the CIT Is What Covers You.

On July 17, Judge Eaton ordered CBP to reliquidate finally liquidated IEEPA entries — but only for the roughly 3,700 companies that have already filed a CIT case, through a case-linked procedure where counsel supplies importer IDs. There is still no CAPE portal function for finally liquidated entries, for anyone. If you haven't filed, nothing currently covers you. TariffIQ™ identifies exactly where your entries stand across Phases 1, 2, and 3 — and whether you need to file a CIT complaint to get covered.

⚡ The Tariff Bureau — Phase 3 Eligibility Strategy
01
Already filed at the CIT? Your finally liquidated entries fall under the July 17 order. We confirm your case is on Judge Eaton's docket, coordinate the importer IDs your counsel must supply, and track your refund.
02
Haven't filed yet? You are not covered under CBP's current position, and waiting for a public Phase 3 opening is not a plan. We assess whether an individual CIT complaint, a timely protest, or the pending class certification motion is your faster path.
03
Unsure which phase applies? We check your liquidation date against the 80-day CAPE cutoff and the 90-day statutory window, and pull your actual duties assessed from ACE report ES-003.
Find Out Where You Stand → IEEPA Recovery Guide
📞 (404) 882-5839  •  Mon–Fri 9am–6pm ET  •  No obligation
~$100B
Sent to Treasury
$128.68B
Accepted for Processing
~3,700
Filed CIT Cases Covered
17.69M
Entries Reliquidated
19,726
Certified, Stuck at Treasury
Alex Monroe - AI Trade Analyst, The Tariff Bureau
Alex Monroe
AI Trade Analyst • TariffIQ™
Online
Phase 3 has been ordered, but the portal function isn't live yet. Here's what that means for you:

• Already filed a CIT case — your finally liquidated entries fall under the July 17 order. Let's confirm your docket status.
• Haven't filed at the CIT — nothing currently covers you. We'll look at an individual complaint, a protest, or the pending class action.
• Not sure which phase you're in — tell me your liquidation dates and I'll walk through Phases 1, 2, and 3 with you.

Tell me your CIT filing status and liquidation timing, and I’ll tell you exactly where you stand.

AI-powered analysis • Not legal or brokerage advice • Learn more

▶ Alex Monroe • TariffIQ™ Overview

Alex Monroe • AI Trade Analyst • TariffIQ™ • Not legal advice

Wire Intelligence • Updated August 14, 2026

Latest National & International Updates

Live intelligence from the wire services and the court docket — curated for U.S. importers navigating CAPE and the ongoing IEEPA refund landscape.

CBP • Aug 4 Declaration to the CIT
💰 ~$100B Sent to Treasury • August 4, 2026
CBP: $128.68B Accepted for Processing, Approximately $100B Certified and Sent to Treasury
In the August 4 declaration of Brandon Lord filed in Freestyle World (1:26-cv-01088, ECF 24), CBP reported that as of 3pm ET on July 31, $128.68 billion in potential and certified refunds had been accepted for processing in CAPE, of which approximately $100 billion in duties plus interest was certified and sent to Treasury for disbursement. CBP states its financial accounting system shows Treasury regularly disbursing those certified refunds.
August 4, 2026 • Lord Declaration, CIT No. 1:26-cv-01088, ECF 24
Section 338 • Canada
🔴 Effective in 5 Days — Aug 19, 2026
Section 338 Tariffs on Canadian Goods — 50%, No USMCA Carve-Out, No Expiration Date
Three proclamations signed July 20 impose an additional 50% ad valorem duty on separate sets of Canadian-origin goods — tied to disputes over motor vehicles, alcohol, and dairy, but reaching well past those headline categories into the annexes. Effective 12:01 AM ET August 19, 2026 for goods entered for consumption or withdrawn from warehouse for consumption. USMCA-qualifying goods get no relief, and Section 338 carries no fixed expiration. Excluded: energy, potash, fish, critical minerals, and goods already subject to Section 232. FTZ trap: covered goods admitted to a foreign trade zone on or after August 19 must enter under privileged foreign status (19 C.F.R. 146.41) or they take the 50% on consumption entry.
July 20, 2026 • Presidential Proclamations (3) • Effective Aug 19, 2026
CBP • ACH Enrollment
⚠️ Stuck Refunds Doubled in One Month
19,726 Certified Refunds Worth ~$1.6B Cannot Be Paid — No ACH Information on File
As of July 31, CBP reported 19,726 refunds totaling approximately $1.6 billion that have not been transmitted to Treasury because the importer of record or its authorized CBP Form 4811 designee never provided Automated Clearing House account information. That figure was 9,837 a month earlier — it roughly doubled while CAPE volume climbed. This is entirely self-inflicted and entirely fixable: enrollment happens in the ACE Portal under the ACH Refund Authorization tab.
August 4, 2026 • Lord Declaration ¶6 • Compare July 13 Decl. ¶6
CAPE • Phase 3 Status
🔴 Portal Function Still Not Live
Phase 3 Was Ordered, Not Launched — Finally Liquidated Entries Still Aren't Accepted in CAPE
Two different things are being conflated across the trade press. The July 17 order is a case-linked reliquidation procedure covering the ~3,700 filed CIT plaintiffs. A CAPE Phase 3 portal function that would let any importer file on finally liquidated entries does not exist yet. CBP's August 4 progress report describes only the June 29 reconciliation deployment, and CBP's July 23 trade information notice still lists entries for which liquidation is final among those not accepted on a CAPE Declaration. CBP's own end-of-July target passed without a new date.
August 4, 2026 • Lord Decl. ¶7 • CBP Trade Information Notice, July 23, 2026
CAPE • Volume & Validation
📊 25.1M Entries Accepted • As of July 31
252,496 Declarations Filed — and 5.02 Million Entries Failed Entry-Level Validation
Of 252,496 CAPE declarations submitted, 178,213 passed file validation. Those covered 25.1 million entries accepted for IEEPA duty removal, of which 17.69 million have since been liquidated or reliquidated without IEEPA duties. But 5.02 million entries failed entry-level validation — primarily because the entry date fell outside CBP's 90-day reliquidation authority, the entry carried no Chapter 99 HTS number used to assess IEEPA duties, or the entry was already on a prior declaration. A rejected entry is not a denied claim, but nobody at CBP will chase you about it.
August 4, 2026 • Lord Declaration ¶¶3–4
Fed. Cir. • Voluntary Dismissal
✅ Appeal Dismissed • July 28, 2026
Federal Circuit Dismisses Appeal No. 2026-1898 — Underlying Injunction No Longer Challenged in That Case
The Federal Circuit granted the government's own unopposed FRAP 42(b)(2) motion to voluntarily dismiss Appeal No. 2026-1898 (Euro-Notions), with mandate issued the same day. The underlying CIT case had already been voluntarily dismissed July 16. Nos. 2026-1895 (lead), -1897, and -1899 remain consolidated and active — this dismissal narrows the appeal, it does not end it. DOJ's opening brief was due August 3; as of August 14 it is not confirmed filed on the docket.
July 28, 2026 • Fed. Cir. Order, No. 2026-1895, Doc. 17
CIT • Lead Case Designation
📌 Oral Argument Aug 19
Freestyle World, Inc. v. United States Is the Lead IEEPA Refund Case — Argument This Month
Judge Eaton designated Freestyle World, Inc. v. United States (1:26-cv-01088) as the lead case guiding how the CIT handles the broader IEEPA refund docket, including the pace and scope of Phase 3 reliquidation. CBP's August 4 progress report was filed in this docket. Oral argument on the class certification question has been ordered for August 19, 2026 — the same day the Section 338 duties take effect.
2026 • CIT Docket, 1:26-cv-01088
Rate Verification • ACE ES-003
⚠️ Don't Assume the Announced Rate
Announced Country Rates Are Not the Same As What You Actually Paid
IEEPA rates shifted repeatedly throughout the affected period — a single "announced rate" for a country is a snapshot, not a constant. Before estimating any refund, pull ACE report ES-003 to confirm the actual duties assessed on your specific entries. Any estimate built on headline rates, including ours, is a starting point and nothing more.
Ongoing guidance • CBP ACE Secure Data Portal
Liberty Justice Center
⚖️ Two Legal Fronts
Liberty Justice Center Now Litigating on Two Separate Fronts
Liberty Justice Center's CIT class certification motion seeking to unlock refunds for importers stuck outside CAPE remains pending, with the government's opposition filed July 28 and argument ordered for August 19. Separately, the organization has filed a distinct challenge to the new Section 301 forced-labor tariffs that replaced Section 122 on July 24. These are two different cases addressing two different tariff regimes.
2026 • CIT / Liberty Justice Center filings
USTR • Tariff Regime Change
⚠️ Section 122 Expired • July 24, 2026
Section 122 Expired — Replaced Same-Day by New Section 301 Tariffs on 60 Countries
Section 122's 10% global tariff expired by statute at 12:01 AM EDT on July 24, its hard 150-day limit. President Trump signed a memorandum July 23 directing USTR to impose new Section 301 tariffs of 10% or 12.5% on 60 countries — ~99.4% of U.S. imports — effective the same instant Section 122 lapsed. USMCA and CAFTA-DR textile/apparel goods are exempt, along with 471 additional HTS subheadings. Goods already subject to Section 232 are EXEMPT from the new 301. Brazil separately got its own 25% tariff July 22. Note that Section 338 duties appear to stack on top of Section 301.
July 24, 2026 • USTR / Presidential Memorandum • CBP CSMS #69326983
CBP • CAPE Phase 2
🟢 2.2M Reconciliation Entries Filed
Reconciliation-Flagged Entries Are Moving — 2.2 Million Filed and Set for Processing
CBP deployed the reconciliation expansion at 5am ET June 29, per CSMS #69066837, covering flagged entries (types 01, 02, 06) where the Type 09 reconciliation entry has not been filed and the entry is unliquidated or liquidated within 80 days. As of July 31, 2.2 million reconciliation-flagged entries had been successfully filed in CAPE and set for processing. If your reconciliation deadline is inside 30 days, CBP's guidance is to prioritize the Type 09 filing — once it's filed, the underlying entries drop out.
June 29, 2026 • CSMS #69066837 • Lord Decl. ¶7 (Aug 4)
U.S. Senate • S.3905
Legislative Backstop • Not Yet Enacted
Tariff Refund Act of 2026 (S.3905) — 180-Day Refund Mandate Independent of Appeal
S.3905 would require CBP to refund all IEEPA duties within 180 days with statutory interest, creating a priority queue for small businesses. The bill has not been enacted. If passed, it would function as a legislative backstop independent of the Federal Circuit appeal.
May 2026 • U.S. Senate / Sidley Austin LLP
PRNewswire • 117 Partners
Claims Market • May 4, 2026
117 Partners (Savannah, GA) — $1B+ Closed — Buying IEEPA Claims for Immediate Cash
Savannah, GA-based 117 Partners LLC closed over $1 billion in distressed IEEPA transactions. A secondary claims market is actively forming — importers needing immediate liquidity can monetize claims rather than wait for CBP processing.
May 4, 2026 • PRNewswire • Savannah, GA
Legal Tracker • Updated August 14, 2026

Key Court Cases & Regulatory Developments

The rulings, orders, and filings directly shaping your refund rights and CAPE filing eligibility.

Supreme Court • Landmark
Learning Resources, Inc. v. Trump
607 U.S. ___ • No. 24-1287 • Decided Feb. 20, 2026

In a 6-3 ruling, the Court held that IEEPA does not authorize the President to impose tariffs. All 2025 IEEPA emergency tariffs were ruled invalid, opening $166–170+ billion in potential refunds. Per declarations filed with the CIT, roughly 330,000 importers of record paid or deposited those duties across more than 53 million entries. This ruling is not under appeal — it stands.

✅ February 20, 2026 • Ruling final • Not under appeal
🟢 Reliquidation Ordered • July 17, 2026
Eaton Order — Case-Linked Reliquidation for ~3,700 Filed Plaintiffs
CIT Senior Judge Richard Eaton • Issued July 17, 2026

Judge Eaton ordered CBP to reliquidate, without regard to IEEPA duties, entries liquidated more than 80 days ago — strictly limited to the roughly 3,700 companies whose IEEPA cases are on his docket. This is a case-linked procedure: plaintiffs' counsel supply importer IDs and CBP accepts the resulting CAPE declarations. It is not a public Phase 3 opening. Importers who have not filed a CIT complaint are not covered, and there is no portal function they could use even if they wanted one.

🟢 Filed CIT cases only • Counsel supplies importer IDs
🔴 CAPE Phase 3 • Not Yet Deployed
Phase 3 Portal Function — No Deployment, No New Date
CBP Trade Information Notice, July 23, 2026 • Lord Decl., Aug. 4, 2026

CBP told the CIT in June that Phase 3 would be ready by end of July. That target passed. The August 4 progress report describes no Phase 3 deployment — paragraph 7 covers only the June 29 reconciliation functionality. CBP's July 23 trade information notice still lists entries for which liquidation is final among the categories not accepted on a CAPE Declaration, alongside drawback claims, open protests, and Type 09 entries. Treat any claim that "Phase 3 is open" as inaccurate until CBP issues a deployment CSMS.

⚠️ Ordered by the court, not deployed by CBP
✅ Fed. Cir. • Dismissed July 28, 2026
Appeal No. 2026-1898 (Euro-Notions) Voluntarily Dismissed
Fed. Cir. Order, No. 2026-1895, Doc. 17 • July 28, 2026

The Federal Circuit granted the government's unopposed FRAP 42(b)(2) motion to voluntarily dismiss Appeal No. 2026-1898, deconsolidated, with mandate issued the same day. The underlying Euro-Notions CIT case had already been voluntarily dismissed July 16. Nos. 2026-1895 (lead), -1897, and -1899 remain consolidated and active — the broader appeal continues.

🔴 Appeal narrowed, not resolved
CIT • Lead Case • Argument Aug 19
Freestyle World, Inc. v. United States
CIT Docket 1:26-cv-01088

Judge Eaton designated Freestyle World, Inc. v. United States as the lead case for the broader IEEPA refund docket, guiding how the court manages the pace and scope of Phase 3 reliquidation. CBP's August 4 CAPE progress report was filed here. The government filed its class-certification opposition July 28, and oral argument is set for August 19, 2026.

📌 Lead case • Oral argument Aug 19
CBP CAPE • Phases 1 & 2 Active
CAPE — Consolidated Administration & Processing of Entries
CBP ACE Secure Data Portal • Phase 1: April 20, 2026 • Phase 2: June 29, 2026

Phase 1 launched April 20 for unliquidated entries and entries within 80 days of liquidation; the reconciliation expansion launched June 29. Per CBP's August 4 CIT filing (data as of July 31): $128.68B accepted for processing and approximately $100B certified and sent to Treasury. 19,726 certified refunds worth ~$1.6B remain stuck solely because the importer or its Form 4811 designee never provided ACH banking information — up from 9,837 a month earlier.

✅ CAPE running • Check your ACH enrollment now
Section 338 • Effective Aug 19, 2026
Section 338 Canada Tariffs — 50%, No USMCA Carve-Out
Three Presidential Proclamations • Signed July 20, 2026

Three proclamations impose an additional 50% ad valorem duty on separate sets of Canadian-origin goods tied to motor vehicle, alcohol, and dairy disputes — with annexes reaching well beyond those categories. Effective 12:01 AM ET August 19, 2026. USMCA preference provides no relief, and Section 338 carries no fixed expiration date, so these stay in place until the President modifies or terminates them. Excluded: energy, potash, fish, critical minerals, and articles already subject to Section 232. Goods admitted to an FTZ on or after August 19 must enter under privileged foreign status or take the duty at consumption entry. This is the first modern use of Section 338, and its legal footing is already being questioned.

⚠️ Effective Aug 19 • Review each annex on its own terms
🔴 Federal Circuit • Consolidated Appeal Active
DOJ Appeal — Nos. 2026-1895 (Lead), -1897, -1899
V.O.S. Selections, Inc. v. United States, No. 26-1895 • Filed June 2–3, 2026

DOJ's Federal Circuit appeal, consolidated under No. 26-1895, targets the CIT’s universal injunction for finally liquidated entries. Appeal No. 2026-1898 was voluntarily dismissed July 28; the remaining three continue. The government's opening brief was due August 3, 2026 — not confirmed filed as of August 14. Separately, Liberty Justice Center's class certification motion (filed June 4, 2026) could unlock refunds for these importers without individual lawsuits; the government filed its opposition July 28 and argument is set for August 19. Importers without filed CIT cases should consult trade counsel immediately.

🔴 Appeal active • Brief due Aug 3, unconfirmed as of Aug 14
Section 301 • Effective July 24, 2026
Section 301 Forced-Labor Tariffs — 60 Countries
USTR / Presidential Memorandum • Effective July 24, 2026

On July 23, 2026, President Trump signed a memorandum directing USTR to impose new Section 301 tariffs of 10% or 12.5% on imports from 60 countries — roughly 99.4% of all U.S. imports — based on a forced-labor enforcement investigation USTR concluded in June. The duties took effect at 12:01 AM EDT on July 24, the same instant Section 122 lapsed. USMCA-qualifying goods and CAFTA-DR textile/apparel goods are fully exempt, along with 471 additional HTS subheadings added after public comment. Goods already subject to Section 232 are EXEMPT from this new 301 — they are not stacked. Brazil received its own distinct 25% tariff effective July 22.

⚠️ Effective now • Check CBP CSMS #69326983 for Chapter 99 headings
Congress • S.3905
Tariff Refund Act of 2026 — Senate Bill S.3905
U.S. Senate • Introduced May 2026 • Not Yet Enacted

S.3905 would require CBP to refund all IEEPA duties within 180 days of enactment, with statutory interest, and create a priority queue for small businesses. The bill has not been enacted. If it were, it would function as a legislative backstop independent of the Federal Circuit appeal.

📅 Introduced May 2026 • Not yet enacted • Monitor Finance Committee
⚡ CAPE Live Statistics • Data as of 3pm ET July 31, 2026
$128.68 Billion Accepted for Processing — Approximately $100 Billion Sent to Treasury
Source: Declaration of Brandon Lord, Executive Director, Trade Programs, CBP — filed August 4, 2026 in Freestyle World, Inc. v. United States, CIT No. 1:26-cv-01088, ECF 24
~$100BSent to
Treasury
$128.68BAccepted for
Processing
25.1MEntries
Accepted
17.69MLiquidated /
Reliquidated
19,726Stuck, No
ACH on File
Aug 19Freestyle Oral
Argument
🚨
CBP Official Scam Warning: CBP has documented active IEEPA refund scams. File only through the official ACE Secure Data Portal at cbp.gov. Verify all communications originate from @cbp.gov addresses. The Tariff Bureau provides advisory and filing-preparation services only — we do not log into ACE on your behalf or request portal passwords.
What We Do

AI-Powered Tariff Recovery Services

From eligibility analysis to CAPE declaration prep — TariffIQ™ identifies your entry status, your refund potential, and your next move across Phases 1, 2, and 3.

IEEPA Eligibility Analysis

AI-driven review of your HTS codes, entry history, and liquidation status to identify which entries are CAPE-eligible today vs. requiring an individual CIT filing or a timely protest.
CAPE Declaration Prep

We build your CAPE Declaration CSV, validate Chapter 99 HTS codes, check ACH enrollment status, and coordinate with your licensed customs broker for ACE submission — in the correct filing sequence.
Refund + Interest Modeling

Detailed financial model of your recoverable duties plus statutory interest under 19 U.S.C. § 1505 — built from your actual ACE ES-003 duties assessed, not announced country rates.
Appeal & Litigation Monitoring

We track the Federal Circuit appeal, the Freestyle World lead case, CAPE deployment CSMS messages, and CBP compliance deadlines so you always know your exact refund status.
IOR & Foreign Manufacturer Advisory

Guidance for DDP foreign manufacturers and non-resident importers navigating CBP ACE registration, ACH enrollment, and Form 4811 authorization.
Broker & Lender Coordination

We connect you with licensed customs brokers and help structure bridge financing against expected refunds for importers with significant cash-flow exposure.
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Find Out Where Your Entries Stand

The July 17 order covers filed CIT plaintiffs, and the Phase 3 portal function still isn't live for anyone else. TariffIQ™ identifies your exact position — CAPE-eligible now, CIT-required, or protest-track — and tells you what to do next. Free. No obligation.

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