Seven months after the Supreme Court struck down tariffs imposed under the International Emergency Economic Powers Act (IEEPA), manufacturers are recovering tariff fees, but few have recovered all of it. Manufacturers Alliance surveyed 25 enterprise-tier manufacturers, and the results show that refunds are arriving faster than expected while gaps, broker delays, and limited explanations from U.S. Customs and Border Protection (CBP) leave many claims unresolved.
The February 2026 Supreme Court ruling ended months of uncertainty that members described in our January 2026 tariff survey. CBP opened Phase 1 of its refund system, the Consolidated Administration and Processing of Entries (CAPE), on April 20 and expanded it to reconciliation-flagged entries (Phase 2) on June 29. Phase 3, covering finally liquidated entries, launches October 6.
The stakes are large. As of March 2026, more than 330,000 importers had paid roughly $166 billion in IEEPA duties. Our findings offer the first look at how manufacturing leaders are experiencing the process from the inside.
Key Insights
- Refunds are flowing, but most are incomplete. Of the manufacturers that filed Phase 2 claims, 76% have been refunded only in part; 24% report full refunds.
- CBP is not explaining the gaps. 54% of the partially refunded companies say CBP provided no explanation, error codes, or line-level detail on the unrefunded portion.
- Speed is a bright spot, pass-through is not. First refunds typically arrived within 30 to 60 days, but fewer than half of companies with broker-handled Phase 1 refunds have received them in full.
- Phase 3 plans may outrun eligibility. 65% of manufacturers intend to file Phase 3 claims, yet only 40% of them have filed their own action at the Court of International Trade (CIT), which Phase 3 currently requires.
Where Refunds Stand
The refund story has shifted from whether money will come back to how much and when. Among our survey respondents, every manufacturer that filed Phase 2 claims has received at least some money, but 52% of respondents are still waiting on part of it, more than three times the 16% refunded in full. Recovery varies widely: 16% of respondents have received more than three-quarters of their claim, while 20% have received half or less.
Phase 2 Refund Status
Source: Manufacturers Alliance survey, September 2026.
This mirrors the national picture. According to CBP's September 15 declaration to CIT, the agency had accepted about $134.7 billion in potential and certified refunds and sent roughly $122 billion to the U.S. Department of Treasury for disbursement as of September 11. That is about three-quarters of the IEEPA duties collected. Trade attorneys interviewed recently expect that 10% to 15% of duties may never be refunded.
For finance teams, partial recovery complicates forecasting and accounting for receivables. It also means refund tracking has become an ongoing reconciliation task, not a one-time filing. Our May 2026 CFO Outlook found 68% of CFOs already cite increased complexity in financial planning and forecasting from tariffs; uncertain refund timing adds to that load.
Why Refunds Fall Short
Uncertainty is the biggest factor in partial refunds. Half of respondents did not receive an explanation about why part of their claim is missing. Timing and scope explain much of the rest: 35% point to entries not yet liquidated or reliquidated and another 35% to entries outside Phase 2 scope.
That uncertainty is understandable with how little detail CBP is sharing. In the Manufacturers Alliance survey, 28% of respondents say they received no explanation, error codes, or line-level details on the unrefunded portion. Only 12% found CBP's information useful in diagnosing the gap; the question did not apply to the remaining 56%.
Perceived Causes of Unrefunded Amounts
Source: Manufacturers Alliance survey, September 2026. Multiple responses allowed.
Validation problems are also significant at the national level. CBP reports that 6.1 million entries failed entry-level validations, mainly because they fell outside the agency's reliquidation window, lacked the Chapter 99 tariff number used for IEEPA duties, or had already been filed. Another $1.3 billion in refunds is on hold because importers have not provided bank account details.
Without line-level feedback, trade teams must reconcile refunds entry by entry against their own records to find what is missing. Companies that keep entry-level data clean and monitor CBP's refund reports will be best positioned to recover the rest. As one executive advised peers: "Get in as early as possible and expect delays."
Refund Timing and Broker Pass-Through
Eighty percent of respondents received their first refund within about 60 days of filing; the other 20% did not know the refund timing. In fact, 40% received it within 30 days, and the fastest reported two weeks. Payments are also continuing after the first refund: one company reports receiving refunds weekly since filing, while another noted that early payments were small.
That is faster than CBP guidance suggested. The website advises filers to expect valid refunds within 60 to 90 days of claim acceptance.
Where a broker or filer handled the claim, the money does not always reach the manufacturer promptly. Only 44% of respondents have received their broker-handled Phase 1 refunds in full, while 39% report that some amounts are still held by their broker, and 11% have not yet reconciled.
Status of Broker or Filer Pass-Through of Phase 1 Refunds
Source: Manufacturers Alliance survey, September 2026.
Refund recovery does not end when CBP refunds money. Manufacturers that rely on brokers or buy from suppliers that act as the importer of record, face a second collection step. The Connecticut Business & Industry Association notes that recovering duties passed through in supplier pricing may require contract review or supplier negotiations. With 77% of manufacturers having passed tariff costs on to customers through price increases, the same question is likely to arise downstream.
Phase 3 and Legal Strategy
Most manufacturers plan to keep pursuing refunds. Sixty-five percent intend to file Phase 3 claims, and another 30% are waiting to see how their Phase 2 claims resolve. Only 4% said the expected recovery does not justify the effort.
Plans to Submit Phase 3 Claims
Source: Manufacturers Alliance Survey, 2026. Percentages may not total 100% due to rounding.
But eligibility is in question. CBP's September 15 declaration states that Phase 3 will cover finally liquidated entries filed by plaintiffs for which the CIT has ordered reliquidation. Plaintiffs who submitted an importer of record number by July 30 can file starting October 6. The government has argued that it cannot refund finally liquidated entries without an importer's own lawsuit, and that question remains in litigation. Sixty percent of manufacturers planning Phase 3 claims have not filed a CIT action.
Legal strategies remain split across the full sample: 35% of respondents have already filed at the CIT, 26% are undecided, 26% do not intend to, and 13% are waiting on class certification rulings.
For manufacturers with finally liquidated entries, the route to recovery may run through the courts, not the portal. Companies counting on Phase 3 without a CIT action should confirm their eligibility with counsel now. Pressure for broader relief is building. Members of Congress wrote to CBP on September 9 urging action on administrative delays, and the Cato Institute has flagged that many smaller firms have struggled to obtain refunds through CAPE. As one respondent asked: "What does the process and progression behind Phase 3 look like?"
61%
of respondents plan to use in-house trade or compliance teams to prepare and submit their Phase 3 claims.
Conclusion
The September 2026 findings show that the IEEPA refund process is working, but unevenly. Manufacturers that filed early are seeing money arrive faster than CBP's own guidance suggested. Yet most are still missing part of their claims, often without an explanation, and broker pass-through adds another layer of complexity and delay.
The next phase raises the stakes. With Phase 3 limited for now to plaintiffs with court-ordered reliquidation, manufacturers' litigation choices may determine how much of the remaining money they recover. Many companies planning Phase 3 claims have not yet taken the legal step that currently unlocks it.
For an industry that carried much of the tariff burden, these details are essential. Manufacturing accounts for 19 of the top 25 most tariff-exposed subsectors in the U.S. economy, and just a year ago, 80% of manufacturing CEOs ranked increased cost pressure as their top short-term challenge from tariffs. Recovering what was unlawfully collected is now part of managing that cost, and it requires the same discipline in data, compliance, and legal strategy that manufacturers have applied to the tariffs themselves.
AI Transparency:
Data and content for this article was analyzed with assistance from an AI tool and reviewed by the research team.
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