US IEEPA Tariff Refunds Open to Older Entries From October 6, 2026: A Leather Jacket Buyer Brief

US Customs and Border Protection (CBP) will deploy Phase 3 of its IEEPA refund system on October 6, 2026, the agency told the Court of International Trade on September 15, 2026. The phase reaches finally liquidated entries, and it matters to leather jacket buyers whose 2025 entries carried an IEEPA duty line.

What the Supreme Court Changed

On February 20, 2026, the Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA does not authorize the President to impose tariffs. CBP had collected those duties under executive orders and Chapter 99 provisions of the Harmonized Tariff Schedule since February 3, 2025, making the collection unlawful.

IEEPA tariffs assessed between February 3, 2025 and February 24, 2026 total an estimated USD 166 billion across more than 53 million entry summaries, a volume CBP could not process entry by entry. The Federal Circuit issued its mandate on March 2, 2026, and the Court of International Trade directed CBP to liquidate or reliquidate the affected entries without the IEEPA duties.

CBP's answer was CAPE, the Consolidated Administration and Processing of Entries, built inside the Automated Commercial Environment (ACE). It consolidates refunds, with interest, by importer and liquidation date. CBP declared it ready on April 20, 2026 and published the details in a Federal Register notice on the IEEPA refund worksheet.

What Opens on October 6, 2026

CAPE has been switched on in stages. Phase 1 covers certain unliquidated entries and entries liquidated within 80 days. Phase 2, live since June 29, 2026, covers entries flagged for reconciliation whose reconciliation entry is not yet on file. Phase 3 reaches finally liquidated entries.

The 80-day line is built into ACE. A declaration is accepted for entries liquidated within the preceding 80 days, which leaves CBP time to reliquidate them by day 90, the voluntary reliquidation period set by 19 U.S.C. 1501. Older entries are rejected in ACE as being in final liquidation status, the group Phase 3 reaches.

CBP's September 15 filing links Phase 3 to importers that filed complaints at the Court of International Trade and received reliquidation orders. Importers that gave CBP a valid importer of record number by July 30, 2026 may file declarations from October 6; CBP will issue instructions for later submissions.

What Leather Jacket Importers Should Check Now

Only the importer of record, or the licensed customs broker that filed the entries, may file a CAPE declaration; an attorney cannot. The declaration is a comma-separated file listing entry numbers, uploaded in the ACE Portal rather than through the Automated Broker Interface. One declaration carries up to 9,999 entries, cannot be amended after acceptance, and an entry may appear on only one accepted declaration.

Payment depends on bank data. Refunds must be issued electronically through the Automated Clearing House, so a US bank account for refunds must be enrolled in the ACE Portal; without it CBP holds the money.

CBP states that most refunds appear in the designated account 3 to 5 weeks after liquidation or reliquidation, and that valid refunds are generally issued within 60 to 90 days of acceptance, including 45 days of processing and Treasury certification. Interest is added under 19 U.S.C. 1505.

Progress can be followed in ACE with the ES-003, ES-022, REV-603, REV-613 and REV-615 reports. CBP charges no fee and does not email status updates, so a message asking for payment or bank details is a scam; official instructions sit on the IEEPA duty refunds page in ACE.

The 180-Day Clock That Runs Beside CAPE

CAPE does not stop the ordinary customs calendar. A protest under section 514 of the Tariff Act of 1930, 19 U.S.C. 1514, must be filed within 180 days of liquidation, on CBP Form 19 or in the ACE Protest module, and it keeps older entries alive while the court-ordered phases continue.

Entries on an open or suspended protest are not accepted on a CAPE declaration. A refund can also shrink: CBP nets other duties owed on the same entry at liquidation under 19 CFR 159.1, and may divert a refund to cover an importer's unpaid debts under 19 CFR 24.72.

Danke publishes briefings on the US import rules that share this calendar, including CPSC eFiling at entry and the forced labor import controls that apply to the same shipments; both are on the industry news page.

For an exporter shipping leather jackets to the United States, the useful part is documentation. Danke, the leather jacket line of Dalian Danke Fashion Co., Ltd, keeps commercial invoices, packing lists and harmonised codes ready so a buyer's broker can match entries to shipments.

The refund claim itself stays with the importer of record. Buyers can reach the Danke export team through www.dankeleatherjacket.com or on WhatsApp at +86 13234076432.

Which entries qualify for a CAPE refund today?

Unliquidated entries, entries liquidated within the preceding 80 days, and entries flagged for reconciliation with no reconciliation entry on file, which were added on June 29, 2026.

What if my IEEPA entries liquidated more than 80 days ago?

Those are the entries Phase 3 covers from October 6, 2026. CBP ties that phase to importers that filed at the Court of International Trade and received reliquidation orders, so an importer that did not file should check the 180-day protest window for each entry.

Does Danke file US customs refund claims for buyers?

No. The importer of record or its licensed customs broker files the CAPE declaration. Danke provides the commercial documents behind each shipment, and the export team answers document questions on WhatsApp at +86 13234076432.