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Clear out junk files and repair common Windows errorsFree Scan →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →“Keep your receipts” was sound advice for technology businesses facing possible refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). But receipts alone do not establish a right to a refund, and a consumer who paid more for a product is not automatically entitled to money from U.S. Customs and Border Protection (CBP). Refund handling depends on the customs entry, the importer of record and, in some cases, court action. As of October 8, 2026, the newest detailed process update available for this article was dated July 24, 2026.
What did the original advice mean?
On November 21, 2025, Ars Technica reported that the Consumer Technology Association (CTA) had urged technology firms to preserve receipts and document tariff payments while the legal status of certain tariffs remained unsettled. CTA CEO Gary Shapiro said: “If plaintiffs prevail in this case, I hope to see the government keep it simple and ensure that retailers and importers get their tariff payments refunded swiftly and with as few hoops to jump through as possible,” Shapiro said.
The recordkeeping advice was precautionary. It did not mean a refund had been approved, identify which businesses would qualify or guarantee that a retailer would pass any refund to customers. For a business, “keep your receipts” should include both proof of payment and the customs records that connect a payment to a specific import entry.
What changed after the 2025 report?
The Supreme Court ruled on February 20, 2026, that IEEPA did not authorize the tariffs at issue. Subsequent Court of International Trade (CIT) orders and CBP procedures addressed refunds for duties already paid under that authority. This later ruling did not mean that every tariff imposed under every law was invalidated.
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The 2025 report also covered prospective semiconductor tariffs under a Commerce Department investigation. That was a separate tariff question from refunds of duties already collected under IEEPA. The later IEEPA ruling, by itself, does not establish the status of tariffs imposed under other authorities.
Who may receive a CBP refund?
CBP refund administration is tied to the importer of record and the relevant customs-entry records. The importer of record is the party identified as responsible for the import entry; it may not be the consumer who ultimately bought the product or the retailer that sold it. A higher retail price does not, on its own, make a customer eligible for a CBP refund.
Whether an importer can recover duties depends on the entry’s status, whether the entry is eligible for the relevant CBP processing phase, and whether the importer has a CIT case or order. The available status updates do not establish a blanket right to refunds for all IEEPA duties or a consumer reimbursement process.
How did the refund routes differ as of July 2026?
The following distinctions reflect a July 24, 2026 legal update. They describe the framework reported at that time, not a determination that a particular entry qualifies. CBP’s phased system is called Consolidated Administration and Processing of Entries (CAPE).
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| Entry or case situation | What the July 24, 2026 update reported |
|---|---|
| Not finally liquidated entries | CAPE Phase 1 covered most entries that were not finally liquidated. |
| Reconciliation-flagged entries | CAPE Phase 2 expanded eligibility for certain entries flagged for reconciliation. |
| Other entry types | Some entry types remained ineligible for CAPE at that point. |
| Finally liquidated entries with a CIT case | Importers who had filed cases were receiving CIT reliquidation orders, according to the July update. |
| Finally liquidated entries without a CIT case | The government’s appeal left recovery for non-litigants with some finally liquidated entries uncertain in the July update. |
Liquidation is CBP’s process for finalizing an entry and determining the duties owed. Because the available update distinguishes entries that are “not finally liquidated” from “finally liquidated” entries, an importer should verify the exact status of each entry rather than relying on a general description of its shipment or tariff payment.
What refund figures had been reported?
CBP figures summarized by BDO on June 5, 2026, said the agency had accepted about $85 billion in potential and certified refunds for processing. Claims totaling $20.6 billion had completed CAPE and been sent to Treasury for disbursement. These were figures reported for that date, not an October 2026 total or a promise that every accepted claim would be paid.
A separate update from Davis Wright Tremaine reported CBP figures for July 10, 2026: accepted CAPE claims covered nearly three-quarters of the $166 billion in IEEPA duties collected, and approximately $86.3 billion had been refunded in duties plus interest. Those figures use a later date and a different measure than BDO’s June report; they should not be combined into one snapshot.
The detailed process information available here does not establish the status of the government’s appeal, later CAPE phases or refund totals after the dates above. It also does not provide a statistic specific to technology companies’ tariff payments or refunds.
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What records should a business preserve?
Keep records that let the business identify the importer of record, match a payment to an entry and support any claim or review. Useful records include:
- Receipts, invoices and other documentation of tariff or duty payments.
- Customs-entry records and related documents for the imported goods.
- Records identifying the importer of record for each relevant entry.
- Entry-status information, including whether liquidation is final and whether an entry was flagged for reconciliation.
- Any records of a CIT case or order tied to the entries.
The key is being able to connect the payment documentation to the specific entry and its current status. Businesses can use existing accounting and customs-record systems; the cited advice does not establish a need to purchase a particular recordkeeping product.
What should an importer do next?
- Identify the importer of record. Confirm which entity is named for each relevant customs entry rather than assuming the retailer, customer or parent company is the claimant.
- Gather payment and entry records. Match receipts and payment documentation to the customs entries and preserve the records together.
- Check entry status and type. Establish whether each entry is not finally liquidated or finally liquidated, whether it has a reconciliation flag, and whether its type was included in a CAPE phase.
- Check for court filings or orders. Determine whether the importer has a CIT case or reliquidation order relevant to finally liquidated entries.
- Verify current agency and court developments. The July 24, 2026 update does not settle later appeal developments or subsequent CAPE phases, so businesses should confirm current instructions before deciding how to proceed.
For a high-value or complicated claim involving entry audits, CAPE submissions or litigation, a customs or international-trade specialist may help assess the records and procedural options. The need for paid assistance depends on the business’s circumstances; the available information does not make it necessary for every importer.
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