The IEEPA tariff refund has two components an importer can affect. The principal amount is the duty actually paid, and that number is whatever it is, fixed by the entries on file. The 6 percent statutory interest is the other component, and it accrues until the refund is issued. That second number is where filing timing matters.
The math on the interest is the part most importers have not yet run. It changes how aggressively a finance team should be pushing trade compliance to get the entry-data work done now.
How the interest actually accrues
The Learning Resources v. Trump ruling included a 6 percent statutory interest provision on refundable IEEPA duties. The interest starts accruing from the date the duty was paid to CBP. It continues accruing until the refund is issued.
This is not a small line item on a meaningful refund position.
A company that paid $5 million in IEEPA tariffs across 2025 entries has accrued roughly $300,000 in statutory interest by May 2026, 12 months after the average payment date. If CAPE opens in August 2026 and the company files in the first week of the window, with CBP issuing the refund 90 days later, the interest stops accruing around November 2026, at which point it would total approximately $450,000 to $500,000 depending on the actual payment dates of the entries.
If the same company waits until the last week of the filing window to submit, and then gets caught in a 6 to 12 month CBP processing queue because the filing was less clean than the early filings, the interest continues accruing the entire time. The total interest captured could exceed $700,000, with the difference coming directly out of the company's working capital position during the wait.
The interest is real money. Most companies have not yet modeled it.
Why the early-filing slot matters
CBP's announced filing window for IEEPA refunds, once CAPE goes live, is 45 to 60 days. That is the window during which the standard refund-filing process accepts claims. After the window closes, refund recovery shifts to the protest and appeal process, which is slower and more contested.
Inside the 45-to-60 day window, CBP's processing pipeline does not work first-in-first-out in the way most people assume. It works by claim quality.
Claims that arrive with clean entry data, clean IEEPA attribution, clean liquidation status, and clean importer-of-record verification go through the pipeline directly. CBP's review is a quality check, not a reconstruction exercise.
Claims that arrive with reconciliation issues (mixed duty codes that were not separated, corrected entries with version mismatches, payment record discrepancies) get flagged for additional documentation. The clock on the company's interest does not pause while CBP waits for the documentation. The clock keeps running, but the refund delays.
This is why the well-prepared importers are pushing to file in the first week the window opens, with data already organized. The interest math rewards the early filer with clean data, not the early filer with messy data, and not the patient filer with whatever data shows up at the deadline.
What "clean" actually means
A clean filing has three properties that CBP looks for first.
The IEEPA duties are cleanly separated from Section 232 and Section 301 duties at the line level on each entry. CBP can identify the refundable portion without having to back-calculate from aggregate totals.
The entries are verified against the importer of record's payment records, with any discrepancies reconciled before submission. CBP is not asked to resolve mismatches as part of the filing review.
The liquidation status is identified per entry, with the appropriate procedural path selected (standard refund for unliquidated entries within the protest window, protest for liquidated entries inside the window, separate appeal process for entries outside the window).
Achieving these three properties is the work of the trade compliance team and the customs broker, assembled in the months before CAPE opens. The work is not exotic. It is precise.
What happens to the not-so-clean filings
The companies that submit incomplete or unreconciled filings during the window have two problems.
First, the refund itself delays. CBP routes incomplete filings to additional-documentation queues that move slowly. A company that files with reconciliation issues might receive the refund six to twelve months after a company that filed cleanly in the same week.
Second, the interest math turns against the slow-processing filer. The 6 percent statutory interest accrues during the delay, which is good for the filer in dollar terms, but it accrues on top of working-capital constraints that are usually the reason the refund is being pursued in the first place. The interest cannot be drawn down. It sits on CBP's books until the refund is issued.
For a company that needed the working capital, the slow refund is the worst of both worlds: the cash is not in the account, and the interest is not productive while it accrues.
Why "wait and see" is not a strategy
The most common framing inside companies that have not yet started entry-data work is "we will get organized when CAPE opens." This framing has two problems.
The 45-to-60 day window is not enough time to assemble entry data and file. It is enough time to file data that is already assembled. Companies that arrive at the window without organized data spend the window scrambling, which produces messy filings, which produce slow refunds, which compound the working-capital problem.
The customs broker capacity inside the window will be heavily constrained. Every customs broker that filed IEEPA-affected entries in 2025-2026 will be doing refund work simultaneously during the same window. Brokers will prioritize the clients that came prepared. The "wait and see" client will be at the back of the broker's queue precisely when the queue is longest.
A "wait and see" approach is functionally a decision to file late, with messy data, into a constrained processing pipeline. The 6 percent interest will partially compensate for the delay, but the working-capital position will be worse during the delay than it needs to be.
What "structured early filing" looks like
For mid-market importers in the affected industries, the path that captures the cleanest refund position with the least working-capital strain has a specific shape.
The trade compliance team and the customs broker complete entry-data organization in the months before CAPE opens. The data is refund-ready by August 2026, based on current CAPE timeline projections.
The CFO or VP Finance evaluates the recovery path options. The three real choices are in-house wait on CBP, broker-led standard filing, or structured filing through a capital partner that advances the expected refund as upfront liquidity.
If the company chooses the structured path, the diligence process begins immediately, in parallel with the entry-data work. The diligence reviews the refund position, the entry-data quality, the corporate structure of the importer of record, and the timing of the expected funding. By the time CAPE opens, the diligence is complete and the structure is ready to fund.
When CAPE opens, the filing submits in the first week of the window. The capital partner advances the expected refund within roughly two to three weeks of the filing. CBP processes the refund on its standard pipeline. When the refund is issued, the capital partner collects from CBP, the working-capital position has been productive for months, and the company has captured the most of the 6 percent statutory interest that the timing allows.
This is one path. The in-house and broker-led paths work for some companies. The structured path works best for companies that want the working capital sooner and want specialized capacity during a constrained processing window.
What the math looks like at scale
A mid-market apparel importer with $30 million in 2025-2026 imports, paying an average 12 percent IEEPA-attributable rate, is sitting on roughly $3.6 million in refundable principal.
By the time CAPE opens (projected mid-to-late 2026), statutory interest on the principal would have accrued to roughly $180,000 to $220,000, depending on the actual payment dates across the entries.
If the company files cleanly in the first week of the window and CBP processes the refund within 90 days, the interest stops accruing at approximately $240,000 to $280,000. Total refund: roughly $3.85 million to $3.88 million.
If the same company waits, files messy, and gets caught in a 9-month processing delay, the interest could grow to roughly $360,000 to $400,000. Total refund: roughly $3.96 million to $4.0 million.
The difference in total refund is roughly $120,000 to $160,000. The difference in working capital received in a timely manner is roughly $3.85 million versus $3.96 million arriving 12 to 15 months later. Most CFOs will trade $120,000 of additional interest for getting $3.85 million on the balance sheet 9 months sooner.
The structured path captures both: clean early filing for the bulk of the principal-plus-interest position, and upfront liquidity within weeks of the filing.
The honest framing
Stone Path facilitates the introduction to a vetted capital partner for importers evaluating the structured filing path. Stone Path does not provide legal advice on tariff classification, does not file refund claims directly, and does not advance capital. Those are the capital partner's lanes, supported by partner law firms where applicable.
Industry projections currently point to the practical filing window closing in early November 2026, based on the projected CAPE timeline and the 180-day appeal period that follows the filing window. After that, the procedural path to refund recovery becomes substantially harder. The companies positioned to file early are the companies that capture the cleanest version of the refund. The companies that wait are the companies that scramble.
Walk through what a structured filing path looks like for your import volume and we will scope the timing against your specific entry profile and working-capital position.