The Liberation Day tariff refunds have now reached $100bn (£78bn), with US Customs and Border Protection (CBP) processing repayments to businesses after a February Supreme Court ruling struck down the broad import levies as unlawful. The headline figure is large. The fuller picture is more complicated.
The Scale of Liberation Day Tariff Refunds
According to CBP official Brandon Lord, writing in a filing with the Court of International Trade, the agency had accepted $128.68bn in refund claims through its dedicated portal as of 31 July, paying out $100bn of that total. The refund portal, formally named the Consolidated Administration and Processing of Entries (CAPE), was launched in late April and had by that date received 252,496 refund declarations covering more than 25 million import entries, Lord stated.
But the total universe of IEEPA tariff revenue that could ultimately be refunded stands at an estimated $166bn, according to CNBC, citing the same court filing. The gap between what has been paid and what may eventually be owed is therefore still very wide. Some $29bn in potential refunds is under active review by trade authorities, while a further $1.6bn is stalled simply because importers have not yet supplied their banking details.
More than 330,000 importers paid IEEPA tariffs on over 53 million entries in total. CAPE has so far processed claims covering fewer than half of those entries, suggesting the operation is nowhere near complete.
Big Brands First, Smaller Importers Still Waiting
The largest refunds have flowed quickly to corporations with the resources to navigate the process. Apple received approximately $2.2bn in IEEPA tariff refunds last quarter, according to CBS News reporting cited by CNBC. Nike received approximately $300m. Amazon, meanwhile, collected roughly $600m in the second quarter, a figure that chief financial officer Brian Olsavsky attributed partly to the company’s early inventory build-up before tariffs took effect and partly to the fact that Amazon does not hold importer-of-record status for most goods listed on its marketplace.
Olsavsky said on Amazon’s second-quarter earnings call: ‘In cases where we did see an increase in costs due to tariffs, we largely absorbed these costs rather than pass them on to customers.’ Where Amazon can establish a direct link between specific import charges and what shoppers paid, it will issue direct reimbursements; elsewhere, the funds will go towards lower store prices, Yahoo Finance reports.
Third-party sellers, who account for more than 60% of goods sold on Amazon’s marketplace, are in a different position. Many of those sellers import directly, were forced to raise prices during the tariff period, and have filed their own separate refund claims through CAPE.
The disparity between what large companies have already recovered and what smaller importers are still chasing sits at the centre of active litigation. The CBP filing was submitted in a lawsuit brought by Freestyle World, a California-based importer seeking class-action status on behalf of smaller businesses that paid IEEPA tariffs and claim they face barriers accessing refunds through CAPE. The government argues the class certification request came too late and is procedurally invalid.
The Department of Justice has added a further complication. In June, it filed an appeal against a Court of International Trade order requiring refunds to cover all entries, arguing that the court lacks jurisdiction to direct CBP to provide refunds for finally liquidated entries. If that argument prevails, a portion of the $166bn total could remain permanently out of reach for some importers.
A Policy in Transition, Not Resolution
The tariff landscape has not simply reverted to the status quo ante. After the Supreme Court invalidated the IEEPA levies in February, the Trump administration introduced a 10% universal tariff as a holding measure. Those expired late last month and were replaced by new tariffs on 60 trading partners, justified on the basis that those partners had failed to adequately address forced labour practices. Days before that, a 50% tariff on Canada was imposed, according to BBC News.
The refund process is, in short, a settlement of one legal chapter while another is being written. The $100bn paid is real money flowing back to businesses. The $66bn still outstanding, the unresolved litigation over finalised entries, and the new tariff regime layered on top of it all suggest that American importers are some way from knowing what their true cost base actually is.
