The Supreme Court gave every furniture importer in America a straightforward answer on February 20: the government owes you back every IEEPA dollar it collected. But “legally owed” and “money in your bank account” are separated by a new refund system that isn't built yet, an appeal deadline that could freeze everything, and a stack of paperwork that won't file itself.
The scale is staggering: 53+ million entries from 330,000+ importers over 12 months, totaling $166 billion in duties that the 6-3 Learning Resources, Inc. v. Trump ruling declared unlawful. CBP's new CAPE refund portal won't launch until late April 2026 and will initially cover only 63% of affected entries. For furniture and home furnishings importers specifically, IEEPA tariffs stacked on top of Section 301 duties pushed some Chinese import costs above 170% at peak. Here's the full picture — and exactly what to do about it.
The full IEEPA tariff timeline: twelve months of unprecedented trade disruption
The story begins on February 1, 2025, when President Trump signed three executive orders invoking IEEPA for the first time in history to impose tariffs — not sanctions, not asset freezes, but actual import duties. This was legally unprecedented: no president had ever read IEEPA as granting tariff authority.
EO 14193 imposed a 25% tariff on Canadian imports (10% on energy/potash). EO 14194 imposed 25% on Mexican imports. EO 14195 imposed 10% on all Chinese imports including Hong Kong and Macau, under HTSUS heading 9903.01.24. China's 10% tariff took effect February 4, 2025, while Canada and Mexico tariffs were delayed 30 days.
By March 4, 2025, China's fentanyl tariff doubled to 20% under EO 14228, and the Canada/Mexico tariffs went live.
Then came “Liberation Day” — April 2, 2025. EO 14257 declared a new national emergency based on trade deficits and imposed a 10% baseline reciprocal tariff on virtually all countries effective April 5, plus higher country-specific rates on 57 nations effective April 9. China's reciprocal rate was set at 34%, stacking on top of the existing 20% fentanyl tariff. For Chinese furniture, the combined IEEPA tariff hit 54% — before adding Section 301 duties on top.
The escalation accelerated at breakneck speed. On April 8, China's reciprocal rate rose to 84%. On April 9, it hit 125%, while all other countries' higher rates paused for 90 days. Chinese imports now faced a combined 145% IEEPA tariff plus Section 301 duties of 7.5–25% and applicable MFN rates. At peak, some Chinese furniture items faced total duties exceeding 170%. Trade effectively froze.
Peak combined rate on Chinese furniture
170%+
145% IEEPA (125% reciprocal + 20% fentanyl) + 25% Section 301 + MFN base rate. Applied April 9–May 12, 2025.
What 170% looked like on a real order
A container of Chinese polypropylene area rugs · declared value $25,000
| Before IEEPA (2024) | Peak IEEPA (Apr 9–May 12 ’25) | Today (post-ruling) | |
|---|---|---|---|
| MFN base rate | $1,125 (4.5%) | $1,125 (4.5%) | $1,125 (4.5%) |
| Section 301 | $1,875 (7.5%) | $1,875 (7.5%) | $1,875 (7.5%) |
| IEEPA (fentanyl + reciprocal) | — | $36,250 (145%) | Refundable |
| Section 122 surcharge | — | — | $2,500 (10%) |
| Total duties | $3,000 | $39,250 | $5,500 |
| Effective rate | 12% | 157% | 22% |
The $36,250 IEEPA portion is what's being refunded. Per container. Across every shipment for 12 months.
A U.S.-China truce on May 12, 2025 dropped the reciprocal rate back to 10%, bringing total IEEPA on China to 30%. When country-specific tariffs resumed on August 7, 2025, negotiated framework deals yielded reduced rates: UK at 10%, Japan and EU at 15%, Vietnam at 20%. A November 4, 2025 deal cut the China fentanyl tariff from 20% to 10%, establishing a total IEEPA rate on China of 20% through November 2026.
Furniture-specific developments arrived on September 29, 2025, when Section 232 tariffs hit wood products: 25% on upholstered wooden furniture and 25% on kitchen cabinets and vanities, effective October 14. These were scheduled to rise to 30% and 50% on January 1, 2026 — but a December 31 proclamation delayed those increases to January 1, 2027. Critically, Section 232 tariffs survive the IEEPA ruling and remain fully in force today.
The endgame arrived February 20, 2026, when the Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA does not authorize tariffs. The same day, Trump signed EO 14389 terminating all IEEPA tariffs and a proclamation imposing a 10% Section 122 global import surcharge for 150 days (through July 24, 2026). IEEPA collection ceased February 24, 2026 at midnight.
Timeline
12 months of IEEPA tariffs
Tap any event for a plain-language explanation.
Current rates
Your current duty stack (as of April 2026)
IEEPA tariffs are gone. Here's what's still on your entries:
If you import
Chinese rugs
~22% total
MFN + 301 + 122
If you import
Chinese upholstered furniture
~47% total
MFN + 301 + 232 + 122
If you import
Turkey, India, Vietnam
~14.5% total
MFN + 122 (no 301)
What the Court of International Trade ruled — and why it changes everything
What the order says now (March 27)
CBP must refund IEEPA duties on all entries — including entries that would normally be permanently closed. This is extraordinary. In standard customs law, once an entry is “finally liquidated” (180 days pass with no challenge), it's sealed forever. Judge Eaton broke that seal.
How it got there: The pivotal case is Atmus Filtration, Inc. v. United States, Court No. 26-01259, before Senior Judge Richard K. Eaton. The order expanded four times in three weeks, each iteration widening importer protections:
March 4, 2026 (Original Order): Directed CBP to liquidate all unliquidated entries without IEEPA duties and reliquidate entries “for which liquidation is not final.”
March 5 (First Amendment): Clarified scope to cover IEEPA duties from the specific executive orders considered by the Supreme Court.
March 20 (Second Amendment): Expanded coverage to include IEEPA duties on imports from Brazil (40% tariff) and India (25% Russia-oil secondary tariff).
March 27 (Third Amendment — the breakthrough): Judge Eaton ordered CBP to reliquidate “any liquidated entries for which liquidation is final” — effectively piercing the normally ironclad barrier of customs finality. Under standard law (19 U.S.C. § 1514), entries that liquidated more than 180 days ago without a protest filing are “final and conclusive.” The March 27 order eliminates this restriction for IEEPA duties entirely.
Key takeaway
Importers no longer need to file individual protests or lawsuits to preserve refund rights on IEEPA duties. The approximately 2,500+ cases filed by 350+ lead counsel at 150+ firms now serve as the vehicle for universal relief — if the order survives appeal.
CBP's CAPE system: how $166 billion gets back to importers
CAPE — the Consolidated Administration and Processing of Entries — is a brand-new automated capability being built inside CBP's Automated Commercial Environment (ACE). It was first disclosed on March 6, 2026, when CBP told the CIT it could not manually process refunds for 53 million entries, estimating that would require 4.4 million staff hours.
System Status
CAPE Readiness Tracker
Target launch: ~April 20, 2026 · Source: CBP CIT filings as of Mar 30
CAPE operates through four integrated components. The Claim Portal (approximately 85% complete) is a new tab appearing in both importer and broker ACE Portal accounts. Importers or their authorized customs brokers upload a CSV file — called a “CAPE Declaration” — listing entry summary numbers for which they claim IEEPA refunds. The system runs two rounds of automated validation: file-level checks and entry-level checks.
The Mass Processing component (approximately 60% complete — the laggard) automatically strips IEEPA-related Chapter 99 HTS codes from validated entry summaries and recalculates duties. The Review and Liquidation/Reliquidation component (approximately 80% complete) sets entries to liquidate on a scheduled date and calculates applicable interest. The Refund component (approximately 75% complete) consolidates refunds by Importer of Record, then issues electronic payments via ACH.
CBP's target for accepting CAPE Declarations is approximately April 20, 2026. Once accepted, CBP estimates an up to 45-day window from acceptance to refund issuance. Phase 1 will cover roughly 63% of all IEEPA-affected entries: unliquidated entries, entries within the 90-day voluntary reliquidation window, and entries with suspended/extended/under-review liquidation status.
Phase 1 explicitly excludes finally liquidated entries, entries flagged for reconciliation, entries designated on drawback claims, entries covered by open protests, entries not filed in ACE, and AD/CVD entries where Commerce has already issued liquidation instructions.
ACH enrollment is mandatory
As of March 26, 26,664 importers have enrolled for electronic ACH refunds — representing 78% of IEEPA-affected entries by value (~$120 billion). But with 330,000+ total affected importers, the vast majority remain unregistered. CBP no longer issues paper refund checks (discontinued February 6, 2026). Importers without ACH enrollment will have refund payments rejected.
Key customs terms every furniture importer needs to understand
The IEEPA refund process involves specialized customs terminology that can be confusing even for experienced importers. Here's a plain-English reference for the terms that matter most.
Reference
Customs Terms Glossary
The paperwork that tells CBP exactly what you imported — what it is, where it came from, and how much duty you owe. Every shipment has one. Your entry summary number is basically your receipt, and it's what you'll need to file a refund claim.
Every product imported into the U.S. gets a numerical code that determines what duty rate you pay. A polypropylene area rug and a hand-knotted wool rug have different HTS codes and different duty rates. Think of it like a tax bracket — the code determines what bracket your product falls into.
When the president imposes special tariffs (like IEEPA), they get added to your entry as extra line items under "Chapter 99" of the tariff schedule. These stack on top of your product's normal duty rate. For IEEPA refunds, CBP needs to strip these lines off your entries and recalculate what you actually owe. Codes like 9903.01.24 (China fentanyl tariff) and 9903.01.25 (reciprocal baseline) are the ones being removed.
When your shipment clears customs, you pay duties based on what you think you owe. This payment is technically a deposit — CBP may adjust the amount up or down when they finalize the entry months later (see: liquidation). For IEEPA refunds, the "excess deposit" is the IEEPA portion you paid that's now owed back.
When your shipment arrives, you pay estimated duties based on what you declared. Months later — typically around 314 days — CBP reviews the entry, finalizes the math, and closes the books. That moment is liquidation. Until it happens, the duties you paid are just a deposit. After it happens, CBP has stated what you officially owe.
A shipment where CBP hasn't closed the books yet — your duties are still just an estimate. This is the easiest category for IEEPA refunds: CBP simply finalizes the entry without the IEEPA charges, and the difference comes back to you.
CBP closed the books, but you still have 180 days to challenge the result (by filing a "protest"). CBP also has a 90-day window where it can reopen the entry on its own. During this period, the entry is settled but not sealed — you can still get IEEPA duties back through normal channels.
The 180-day protest window closed and nobody challenged it. Normally, this means the case is permanently shut — no appeals, no refunds, no exceptions. That's what makes the March 27 court order so significant: the judge ordered CBP to reopen even these entries for IEEPA refunds, breaking a rule that almost never gets broken in customs law.
Reopening a closed entry to redo the duty math. This can happen two ways: CBP does it voluntarily (they have a 90-day window after liquidation), or a court orders them to do it. For IEEPA refunds, most entries will be reliquidated — CBP reopens the entry, strips out the IEEPA charges, and recalculates.
Your formal objection to what CBP says you owe. You have 180 days after an entry liquidates to file one. If CBP denies your protest, you can take it to federal trade court. For IEEPA: even though the court order should cover your entries, filing a protest is still the safest way to protect your right to a refund — especially if the government appeals.
A licensed professional who handles your import paperwork with CBP — they file your entries, classify your products, and pay duties on your behalf. For the IEEPA refund, your broker is your most important partner: they have access to your entry data, can submit CAPE claims through their ACE account, and know which of your entries included IEEPA charges.
CBP's online system where all import paperwork gets filed and duties get paid. Think of it as the IRS e-file equivalent for customs. You need an active ACE account to submit IEEPA refund claims through CAPE.
The brand-new refund system CBP is building specifically to handle IEEPA duty refunds. It lives inside ACE. When it launches, you or your broker will upload a CSV file listing the entry summary numbers you're claiming refunds on. CBP then automatically recalculates your duties without the IEEPA charges and sends the difference back via direct deposit.
The electronic payment network through which CBP will issue refunds. Paper checks are no longer an option. You must have ACH refund settings configured with a NACHA-member U.S. bank to receive your IEEPA money back.
The company name on the entry paperwork — the entity CBP considers legally responsible for the shipment. This matters because refunds go to the Importer of Record, period. If a buying agent, trading company, or sourcing office arranged your shipment but your company is listed as Importer of Record, the refund comes to you.
A completely separate refund program (unrelated to IEEPA) where you get duties back on goods that you later export or destroy. Mentioned here only to prevent confusion — if someone tells you to file for drawback on your IEEPA duties, that's the wrong process.
Tool
Which refund path applies to your entries?
Answer the questions below to determine your next step.
Is the entry unliquidated?
Where things stand right now: the April 2026 action checklist
The single most important fact for every furniture importer: refunds are not automatic. You must take specific steps to recover IEEPA duties. Here is what needs to happen, in priority order.
Step 1
Enroll in ACE and ACH refunds immediately.
Without an active ACE Portal account and ACH refund authorization with a NACHA-member U.S. bank, CBP cannot return your money. Visit CBP.gov to create an ACE Portal account (Top Account with Importer sub-account view), then configure ACH refund settings.
Step 2
Compile all affected entry data.
Work with your customs broker to identify every entry from February 4, 2025 through February 24, 2026 that included IEEPA Chapter 99 HTS codes. Document entry summary numbers, HTS codes, IEEPA duty amounts, country of origin, and current liquidation status.
Step 3
Prepare CSV files for CAPE submission.
CAPE requires CSV-formatted uploads. Start formatting your data now so you can submit immediately when the portal goes live around April 20.
Action item
5 questions to ask your customs broker this week
- 1How many of my entries from Feb 4, 2025 through Feb 24, 2026 included IEEPA Chapter 99 HTS codes?
- 2What’s the total IEEPA duty I paid across those entries?
- 3How many of those entries are still unliquidated vs. liquidated vs. finally liquidated?
- 4Are any of my liquidated entries approaching the 180-day protest deadline? If so, can you file protests now?
- 5Are you set up to submit CAPE Declarations on my behalf when the portal opens?
Step 4
File protests on entries approaching the 180-day deadline.
Despite the March 27 order covering finally liquidated entries, the government hasn't appealed yet (deadline: ~May 4, 2026), and an appeal could stay the order. Filing protests within the 180-day window remains the safest protective measure.
Your customs broker can file these on your behalf. Cost is typically modest — often included in broker fees or a few hundred dollars per protest. This is the single most cost-effective protective step you can take.
Step 5
Consider filing a CIT lawsuit.
The government's stated position remains that importers must “file a claim in this court” to receive refunds. Over 2,500 cases have already been filed. Filing preserves refund rights regardless of appeal outcomes.
More relevant for importers with significant IEEPA exposure (six figures+). Many trade law firms are filing on a contingency or flat-fee basis given the volume. The 2,500+ cases already filed may provide universal relief — but “may” is doing heavy lifting, and the government's position is that individual filing is required.
Step 6
Review vendor surcharges and downstream obligations.
The refund creates a chain reaction. Many suppliers added IEEPA surcharges to invoices. Many importers passed costs to wholesale and retail customers. Now the money is flowing backward, and the legal question of who owes whom is unresolved.
What to do now: Review your supplier agreements for surcharge language. Check whether surcharges were labeled as “temporary” or “tariff-related” — both create stronger refund claims. On the customer side, review whether you represented price increases as tariff pass-throughs. Retailers and their attorneys are already organizing.
This is likely to be the “second wave” of IEEPA litigation — contract-by-contract, not a universal court order.
Step 7
Distinguish IEEPA refunds from continuing tariffs.
Section 232 tariffs on upholstered furniture, kitchen cabinets, and vanities (25%, increases delayed to Jan 1, 2027) remain in force. Section 301 tariffs on Chinese goods (7.5–25%) are unaffected. The new Section 122 global surcharge (10%) applies. Only IEEPA-specific duties are refundable.
Calendar
Key dates for furniture importers
CAPE Phase 1 portal opens
Section 301 public hearings
Government appeal deadline
HFA DC Fly-In
Earliest Phase 1 refunds
§122 surcharge expires
§232 furniture tariff increase
Earliest CIT litigation deadline
Risks, appeals, and what's coming next
The government appeal deadline runs through approximately May 4, 2026. Multiple law firms expect an appeal is likely, targeting the scope of Judge Eaton's universal refund order rather than the underlying IEEPA ruling (which the Supreme Court already settled). An appeal could trigger a stay of the CAPE refund process, potentially delaying refunds by 6–18 months or more.
Interest is compounding
Interest accrues on the $166 billion at approximately $650 million per month (6% annual rate), creating enormous fiscal incentive for the government to resolve claims quickly. Historical precedent: when the Supreme Court struck down the Harbor Maintenance Tax in 1998, CBP took four years to publish refund procedures for a mere $730 million — the IEEPA refund is 200 times larger.
The administration's replacement tariff strategy operates on three tracks. The Section 122 bridge tariff (10% global, expiring July 24, 2026) provides temporary revenue but faces legal challenges. New Section 301 investigations launched March 11 target 16 economies for structural excess capacity and 60 economies for forced labor failures, with public hearings April 28–May 5, aiming to replace Section 122 before expiration. Section 232 continues expanding, with pending investigations on pharmaceuticals, wind turbines, robotics, and industrial machinery.
Legislatively, the Tariff Refund Act of 2026 would impose a 180-day deadline for processing refunds. An 18-state attorney general coalition is pushing for automatic refunds with consumer pass-through requirements. The broader consensus: Congress is reasserting its Article I tariff authority, though comprehensive reform remains politically difficult.
For furniture importers specifically, the HFA is hosting a Washington DC Fly-In on May 19–21, 2026 for members to meet with lawmakers on tariffs, tax policy, and regulatory reform.
Data sources for real-time tariff monitoring
Building a tariff-tracking workflow is feasible using publicly available feeds. The most critical sources:
Tariffs aren't going away — but $166 billion in IEEPA duties is
The IEEPA tariff saga represents the largest duty refund event in American customs history — 200 times larger than the previous record. For furniture importers who endured combined rates exceeding 170% on Chinese goods at peak, the refund opportunity is substantial. But the window requires action, not patience.
Three realities define the months ahead. First, CAPE is opt-in, not automatic — importers who don't file CAPE Declarations get nothing. Second, the May 4 appeal deadline is the single biggest variable: a government appeal could freeze refunds for a year or more, while interest compounds at $650 million monthly. Third, tariffs are being rebuilt on different legal foundations — Section 232, Section 301, and Section 122 authorities ensure that furniture importers face a permanently elevated duty environment even after IEEPA refunds arrive. Meanwhile, ocean freight costs are surging due to the Hormuz crisis, adding another layer of pressure on landed costs.
The importers who will recover most efficiently are those acting now: enrolling in ACE/ACH, organizing entry data, preparing CSV files, filing protective protests, and engaging trade counsel. The $166 billion is coming back. The question is whether your share arrives in months — or years.
Disclaimer: This article is for general industry awareness and does not constitute legal, customs, or financial advice. Verify all figures and consult qualified trade counsel before making operational or legal decisions.