U.S. Customs and Border Protection will open its Consolidated Administration and Processing of Entries tool on April 20, 2026, giving importers the first electronic route to reclaim duties paid under the now-invalidated IEEPA tariff regime. CBP confirmed the launch through Cargo Systems Messaging Service bulletin #68315804, with Phase 1 covering certain unliquidated entries and entries within 80 days of liquidation. The government estimated it collected $166 billion from more than 330,000 businesses in IEEPA tariffs that the Supreme Court found unconstitutional in its 6-3 February 20 ruling, and the queue of refund claimants is long.
What the Data Shows
The scale of the refund operation is unprecedented. CBP estimated that processing the refund volume under its existing procedures would require 4,431,161 working hours, equivalent to 533,896 eight-hour workdays, which is why the agency built CAPE as a consolidated electronic system rather than running entry-by-entry claims. Refunds will generally be issued within 60 to 90 days following acceptance of a CAPE Declaration, unless a compliance concern requires further review. Each CAPE Declaration is capped at 9,999 entries, but multiple declarations may be submitted, and only the importer of record or the licensed customs broker who filed the entries can file.
The replacement regime is a different animal. Effective February 24, 2026, the United States imposed a global 10% tariff under Section 122 of the Trade Act of 1974, while terminating the IEEPA duties. Trump said within 24 hours of the initial February 20 announcement that he would raise the rate to 15%, the statutory maximum, but that increase has yet to occur. Because Section 122 was designed to address balance of payments crises, tariffs raised under it expire after 150 days unless Congress extends them. The current duties went into effect on February 24 and expire July 24.
India's position inside this framework is distinctive. Following bilateral talks, India had an IEEPA rate of 18% in early February 2026. The Section 122 proclamation replaced that with a flat 10-percentage-point surcharge on all imports, with no country-specific top-ups. The 26% reciprocal tariff that previously applied to Indian goods hit $77 billion in goods exports, but IT services stayed exempt because software exports are classified as services, not goods under the US Harmonized Tariff Schedule.
What This Means
The asymmetry between goods and services trade is now the defining feature of the US-India commercial relationship. Goods importers are staring at a refund backlog measured in hundreds of thousands of entries, a bilateral trade agreement that has been paused, and a 150-day statutory clock ticking on the replacement tariffs. Services trade has been quietly untouched the entire time.
That matters because the services flow is the larger, faster-growing piece. The India software services export market is expected to grow from USD 158.19 billion in 2025 to USD 165.32 billion in 2026, supported by India's 55% share of global IT outsourcing, a workforce of more than 5 million professionals, and 1,650 global capability centers employing 1.6 million people. Services exports reached USD 387.5 billion in FY25, growing 13.6%, with the services surplus covering nearly two-thirds of the merchandise deficit. None of that is exposed to HTS codes or Chapter 99 provisions. Software delivery, engineering R&D, finance and accounting operations, product teams embedded inside US companies, all of it moves through the services channel. For US companies evaluating the shift, the case for offshoring to India has strengthened precisely because the cost and tariff exposure of goods-based alternatives keeps moving.
And the GCC buildout keeps accelerating right through the tariff noise. UnearthInsights founder Gaurav Vasu noted that tariffs never impacted the setting up of GCCs in India, pointing to 101 new GCCs opened last year, more than in 2024. The India GCC market was estimated at USD 69.85 billion in 2025 and is projected to reach USD 130.50 billion by 2033, growing at 8.1% CAGR, with technology and digital services the largest functional segment at 38.2% share in 2025. For companies in the US deciding where to put their next product team or engineering pod, the math is unambiguous: goods face a tariff regime that may shift again after July 24, while services flow unimpeded. Employer of Record arrangements and direct GCC builds have become the cleanest way to access Indian talent without any customs exposure, because compensation paid to India-based engineers never enters the tariff system in the first place. The broader rationale for why US firms outsource to India now extends beyond cost arbitrage into structural tariff insulation.
The Wisemonk India Investment Intelligence 2026 tracks this shift across capital and talent flows, and the Wisemonk India IT Services Analyst Report 2026 documents the structural tilt of global enterprise spend toward India-based delivery. The picture both reports paint is consistent: the services corridor has decoupled from the goods fight.
What to Watch Next
Three dates anchor the next 90 days. April 20 is the CAPE Phase 1 launch, and the speed at which early refund batches clear will signal whether the 60-to-90-day window holds in practice. July 24 is the Section 122 expiration, and what replaces those duties, whether through Section 232 national security actions, Section 301 investigations, or congressional extension, will set the tariff shape for late 2026. On March 11, USTR initiated Section 301 investigations into the manufacturing practices of 16 jurisdictions including India, and the pace of those proceedings is the real signal for where durable goods tariffs are heading.
The bilateral trade agreement with India is the wildcard. India and the US postponed talks on the proposed interim bilateral trade agreement following the Supreme Court ruling and the Section 122 tariffs, with India's chief negotiator's visit deferred. How Delhi and Washington restart that conversation, and whether a revived BTA touches services at all, will determine whether the current split between tariffed goods and exempt services persists or gets renegotiated.
Court watchers should also track the states' challenge. Twenty-three states, led by New York, sued to block the Section 122 tariffs, arguing the government failed to show a serious balance of payments imbalance required to invoke the statute. The states' cases were heard by a panel at the Court of International Trade on April 10, 2026.
The IEEPA era ended in February, but its accounting tail will run through 2026. What's clearer than the refund math is the structural lesson: building a US company's India footprint through services and talent, rather than physical goods, has been the tariff-proof strategy all along. Every HTS code that moved in the last year is a reminder that the services exemption is the only line that never did.