How to Claim Your IEEPA Tariff Refund: The Complete 2026 Guide for Importers
How to Claim Your IEEPA Tariff Refund: The Complete 2026 Guide for Importers
The biggest tariff refund in U.S. history is now underway. On February 20, 2026, the Supreme Court ruled in *Learning Resources v. Trump* that using the International Emergency Economic Powers Act (IEEPA) to impose broad import tariffs exceeded presidential authority. On March 4, 2026, the Court of International Trade ordered U.S. Customs and Border Protection (CBP) to refund all IEEPA duties collected during the period those tariffs were in effect — approximately $166 billion owed to roughly 330,000 importers.
CBP expects to begin automated refunds by late April 2026. If you imported goods into the United States between March 2025 and February 2026 and paid IEEPA-based duties, you are almost certainly owed money. This guide covers everything you need to know: who qualifies, how the refund process works, what you need to do to ensure you receive your refund, and the timeline you should expect.
Background: What Were the IEEPA Tariffs?
In early 2025, President Trump invoked IEEPA to impose sweeping tariffs on imports from China (up to 145%), Canada and Mexico (25%), and a "reciprocal tariff" structure on most other countries ranging from 10% to 50%. These tariffs were layered on top of existing Section 301, Section 232, and MFN duties.
The IEEPA tariffs were historically unprecedented. IEEPA had never before been used to impose import duties, and legal challenges were filed almost immediately. The Supreme Court agreed to hear the case on an expedited basis and issued its ruling on February 20, 2026, finding that IEEPA's grant of authority to "regulate" international commerce did not extend to imposing tariffs, which are constitutionally a Congressional power.
The ruling was retroactive. All IEEPA-based duties collected from the date they took effect (varying by country, but generally March 2025 onward) through their termination on February 24, 2026, were ruled unlawful and must be refunded.
Who Is Eligible for a Refund?
You are eligible if you were the importer of record on any entry that was assessed IEEPA-based duties between March 2025 and February 24, 2026. This includes duties imposed under the following IEEPA proclamations:
The China-specific IEEPA tariffs (rates ranging from 20% to 145% depending on the date of entry), the Canada and Mexico 25% IEEPA tariffs (in effect March 4, 2025 through February 24, 2026 with various pauses and modifications), and the "reciprocal tariff" IEEPA duties on all other countries (10% baseline plus country-specific escalations up to 50%).
If your customs broker filed entries during this period and IEEPA duties were assessed, you qualify. The refund applies to the IEEPA portion of duties only — base MFN duties, Section 301 tariffs, Section 232 tariffs, and other lawful duties that were collected during the same period are not affected.
How the Refund Process Works
The Court of International Trade's March 4, 2026 order requires CBP to process refunds systematically. Here is how CBP is implementing the refund:
Automated Refunds (No Action Required for Most Importers). CBP is building an automated refund process that will identify all entries with IEEPA duty assessments and calculate the refund amount for each. For entries that have been liquidated (finalized), CBP will issue refund checks or ACH payments to the importer of record. For entries still in unliquidated status, CBP will reliquidate them without the IEEPA duty component.
Timeline. CBP has indicated that automated refunds will begin in late April 2026. The agency expects to process the majority of refunds within 6 to 12 months, with the largest and most complex entries potentially taking longer.
Interest. The Court of International Trade's order includes interest on refunded amounts. Interest accrues from the date of collection to the date of refund at the statutory rate published by the Treasury Department.
What You Should Do Right Now
Even though the process is largely automated, there are several steps importers should take to protect their interests and ensure they receive every dollar owed.
Step 1: Verify your importer of record status. Confirm with your customs broker that your company is listed as the importer of record on all relevant entries. If you used a different entity name, a subsidiary, or a broker-of-record arrangement during 2025, ensure that the refund will be directed to the correct entity.
Step 2: Compile your entry records. Pull a complete list of all entries filed between March 2025 and February 2026. For each entry, note the entry number, entry date, IEEPA duty amount assessed, and liquidation status. Your customs broker should be able to generate this report from their records or from ACE (the Automated Commercial Environment).
Step 3: Reconcile against CBP records. Once CBP begins issuing refunds, compare the amounts received against your records. Discrepancies can occur due to entry amendments, post-summary corrections, or partial liquidations. If the refund amount does not match your records, file a protest with CBP within 180 days of the refund notice.
Step 4: Check your ACH or payment information. CBP refunds are typically issued via ACH to the bank account on file with CBP. Verify that your ACH information in ACE is current. If your banking information has changed since 2025, update it immediately to avoid refund processing delays.
Step 5: Consult a trade attorney if your situation is complex. If you have entries involving drawback claims, Foreign Trade Zone (FTZ) admissions, temporary importation bonds, or other special programs, the refund calculation may be more nuanced. A trade attorney can help ensure you receive the correct amount.
How Much Are You Owed?
The refund amount depends on how much you imported, from which countries, and during which periods the IEEPA rates were in effect. Here are some representative examples:
An importer who brought in $1 million per month of Chinese goods subject to the 20% IEEPA tariff from March through December 2025 would have paid approximately $2,000,000 in IEEPA duties over that period. That full amount, plus interest, is refundable.
A smaller importer who shipped $100,000 worth of Canadian goods in April 2025 at the 25% IEEPA rate would be owed approximately $25,000 plus interest.
To estimate your current tariff exposure under the post-IEEPA regime (Section 122, Section 301, Section 232), use our Duty & Tariff Calculator. Understanding your current rates helps you plan how to deploy the refund capital most effectively.
What About Section 122 — Did It Replace the IEEPA Tariffs?
Yes. On February 24, 2026, four days after the Supreme Court ruling, the President invoked Section 122 of the Trade Act of 1974 to impose a 10% universal tariff on most imports. This replaced the IEEPA tariffs with a legally distinct surcharge. The Section 122 tariff is temporary (150 days, expiring July 24, 2026) and carries a lower rate than most IEEPA tariffs.
The Section 122 tariff has no bearing on your IEEPA refund. They are separate legal actions. You are owed a refund of the IEEPA duties you paid, regardless of what Section 122 duties you may be paying now.
For more on the Section 122 timeline, see our article on Section 122 Tariff Expiration: What Importers Must Do Before July 24, 2026.
Common Questions
Do I need to file a claim? For most importers, no. CBP's automated process is designed to identify and refund all IEEPA duties without requiring individual claims. However, if you do not receive a refund within 12 months of the first automated disbursements, you should contact CBP or file a formal claim.
What if my customs broker is no longer in business? Your refund is tied to you as the importer of record, not to the broker. CBP's records in ACE identify you as the party owed the refund. You may need to work with a new broker or directly with CBP to ensure correct payment routing.
Are there taxes on the refund? Consult your tax advisor. The refund represents a return of overpaid duties, which were likely deducted as a business expense when paid. The refund may need to be recognized as income in the year received. Interest on the refund is generally taxable income.
Can I claim drawback on IEEPA duties I already received refund for? No. If you receive an IEEPA refund on duties that were also the basis for a drawback claim, the drawback must be adjusted. CBP will reconcile drawback claims against IEEPA refunds to prevent double recovery.
For up-to-date tariff rate calculations under the current regime, use our Duty & Tariff Calculator to model your landed costs with Section 301, Section 232, and Section 122 rates.
Frequently Asked Questions
Common questions about how to claim your ieepa tariff refund
When will IEEPA tariff refunds start?
CBP expects to begin automated IEEPA tariff refunds in late April 2026. The majority of refunds are expected to be processed within 6 to 12 months, with complex entries potentially taking longer.
Do I need to file a claim to get my IEEPA refund?
For most importers, no. CBP is building an automated refund process that will identify all entries with IEEPA duty assessments and issue refunds to the importer of record. However, you should verify your ACH information in ACE is current and monitor for receipt of your refund.
How much money is being refunded in total?
Approximately $166 billion in IEEPA duties collected from roughly 330,000 importers between March 2025 and February 2026 is being refunded, plus statutory interest.
Will I earn interest on my IEEPA refund?
Yes. The Court of International Trade's order includes interest on refunded amounts, accruing from the date CBP collected the duties to the date the refund is issued, at the statutory rate published by the Treasury Department.
Does the IEEPA refund affect my current Section 122 duties?
No. The IEEPA refund and Section 122 tariff are separate legal actions. You are owed a full refund of IEEPA duties regardless of what Section 122 duties you are currently paying. The two do not offset each other.
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