CBP Has Accepted $85 Billion in Tariff Refunds — But Only $20.6 Billion Is Certified and Paid. What That Gap Means for Texas Manufacturers.

As of May 22, 2026, U.S. Customs and Border Protection has certified $20.6 billion in tariff refunds with interest — out of $85 billion in total accepted refunds, according to Supply Chain Dive. That $64.4 billion gap is not a bureaucratic footnote. The program is active, CBP is processing and paying certified claims, and interest is accruing on every certified claim in the queue. Manufacturers who have not yet filed are not waiting on a closed window. They are watching interest accumulate on claims they have not submitted.

What Section 301 and Section 232 Refunds Actually Are

Two tariff programs account for the bulk of potential mid-market exposure. Section 301 tariffs were imposed beginning in 2018 on Chinese-origin goods, covering electronics components, industrial equipment, machinery parts, and a broad range of manufactured inputs. Section 232 tariffs, also launched in 2018, applied to imported steel and aluminum. Together, these programs affected virtually every Texas Triangle manufacturer that sourced overseas inputs during the peak years.

A tariff refund is not automatic. It requires a formal filing: either an exclusion request through the Office of the U.S. Trade Representative (USTR), a protest filed with CBP, or a duty drawback claim. Each must be supported by documented proof that the tariff was paid and that the specific product qualified for relief. CBP does not proactively identify eligible filers and issue checks.

The interest accrual feature is what creates urgency. Once CBP certifies a claim, interest accrues on top of the principal refund amount. A manufacturer that files and achieves certification today recovers more total cash than one filing an identical claim six months from now.

Why Mid-Market Operators Are Underrepresented in That $85 Billion

Large enterprises with dedicated trade compliance teams and customs attorneys have been filing and tracking these claims since the tariff programs launched. A $10 billion manufacturer with a global trade department did not miss this. A $40 million industrial fabricator in the Houston metro with a two-person purchasing department very likely did.

The specific enterprise-versus-mid-market breakdown within the $85 billion accepted total is not confirmed by available sources. But the structural reality is clear: filing requires knowing the opportunity exists, locating historical import entry records, correctly classifying shipments by HTS code, and preparing documentation that satisfies CBP's requirements. None of that happens without someone whose job includes trade compliance. Most mid-market manufacturers in the Texas Triangle do not have that person.

This is the gap — and likely the reason the certified-and-paid figure of $20.6 billion reflects, at least in part, well-resourced enterprise filers dominating the queue.

What Your Records Need to Show

Before engaging outside help, the internal question is simple: can your team reconstruct what you paid in tariff duties between 2018 and 2025?

The records that matter:

• Import entry summaries (CBP Form 7501): The official duty payment record for every shipment that cleared customs. Your customs broker should have copies. If you managed clearance in-house, check your document management system or EDI archives.
• Accounts payable records: Duty payments flow through your customs broker as disbursements. Your AP history should reflect duty amounts by invoice and shipment date.
• ERP landed cost data: If your ERP captured landed costs at the line-item or shipment level, those records can cross-reference duty amounts against product classifications and supplier origin.
• HTS classification records: Section 301 and Section 232 exposure is determined by Harmonized Tariff Schedule code. Knowing what you imported and how it was classified is the foundation of any recovery analysis.

If your ERP did not capture landed costs cleanly, or if duty payments were aggregated in AP without shipment-level detail, records reconstruction is harder but not impossible. Customs brokers maintain their own entry records, and CBP's Automated Commercial Environment (ACE) portal holds official entry data. A customs attorney or licensed broker can pull these as part of an initial exposure assessment.

What Is Confirmed, and What Is Not

This is a financial and legal decision, so precision matters.

Confirmed by Supply Chain Dive (May 2026):

• CBP has accepted $85 billion in tariff refunds as of May 2026, revised upward from a prior figure.
• CBP has certified $20.6 billion with interest as of May 22, 2026.
• Claims require documented proof of duty overpayment and timely filing.
• Certified claims accrue interest on top of principal refund amounts.
• This is a one-time recovery opportunity tied to historical overpayments, not a recurring program.

Not confirmed by available sources:

• Specific statutory filing deadlines or window expiration dates for any particular refund category.
• Current CBP processing timelines from submission to certification.
• Whether CBP's backlog is growing, shrinking, or stable.
• Average recovery amounts or rates for mid-market filers.
• Whether the $85 billion total includes duty drawback claims, exclusion refunds, or both.

The filing deadline question is the critical unknown. Duty drawback claims and exclusion refund protests have different statutory windows, and those windows vary by tariff category and entry date. A customs broker or trade attorney can confirm which windows apply to your specific import history and which have already closed. Do not assume all windows are open indefinitely.

The Practical Decision

The decision is not whether to build a trade compliance function. It is whether to commission a one-time retroactive audit.

A licensed customs broker or trade compliance attorney can review your import history, identify shipments with potential refund exposure, assess which filing windows remain open, and prepare or supplement claims. This is a finite engagement, not a permanent hire. Most firms specializing in duty recovery work on a contingency or flat-fee basis for historical audits, though fee structures vary and should be confirmed before engaging.

The trigger to act now is the interest accrual mechanism. A certified claim earns interest back to its certification date. Every month that passes before your claim is filed and certified is a month of interest you will not recover.

The concrete steps, in order:

1. Pull your import records. Request CBP Form 7501 archives from your customs broker for all entries from 2018–2025. Cross-reference against your AP duty payment history.
2. Identify tariff exposure by HTS code. Flag all entries where Section 301 (List 1–4, China-origin) or Section 232 (steel and aluminum) tariffs were paid.
3. Check for prior filings. Confirm with your customs broker whether any exclusion requests, protests, or drawback claims were filed on your behalf. Many mid-market operators do not know what their broker did or did not file.
4. Engage a customs broker or trade attorney. Request a preliminary exposure assessment before committing to a full filing engagement. Ask specifically about applicable filing deadlines for your import categories.
5. Document what you find. Even if recovery exposure is limited, the audit produces a baseline record of your landed cost history with independent value for future sourcing and procurement decisions.

The program is active. CBP is paying certified claims. The question is whether your company's eligible refunds are in that queue — or still sitting in a customs broker's archive waiting for someone to ask.