IEEPA Tariff Refunds: How Importers Can Reclaim 2025 Duties After the Supreme Court Ruling

In February 2026, the U.S. Supreme Court fundamentally changed the outlook for thousands of importers by ruling that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful. For businesses that paid those duties throughout 2025 and early 2026, the decision created an unexpected opportunity to recover significant amounts of money.

The ruling, however, did not trigger automatic refunds. Importers must still determine whether their entries qualify, understand how their shipments were filed and follow the appropriate refund process before applicable filing deadlines expire.

Some importers may have already missed filing deadlines for certain entries, while others still have time to recover qualifying duties. That's why reviewing your import records now is critical. For companies with dozens or even thousands of import entries, waiting too long could mean leaving significant money on the table.

In this guide, we explain what the ruling means, who may qualify for an IEEPA tariff refund, how the filing process works and why acting sooner rather than later matters.

Key Dates At a Glance

Date	What happened	Why it matters
February 4, 2025	Certain IEEPA duties began	Earliest potentially refundable entries
April 5, 2025	Additional reciprocal IEEPA tariffs took effect	Expanded refund eligibility
February 20, 2026	U.S. Supreme Court ruled IEEPA tariffs unlawful (6-3 decision)	Refund opportunity created
February 24, 2026	Collection of IEEPA tariffs stopped	End of the qualifying collection period for these tariffs
April 20, 2026	U.S. Customs and Border Protection (CBP) launched its initial tariff refund filing process	Eligible importers could begin pursuing qualifying refunds
Ongoing	Eligible importers can continue reviewing entries and filing qualifying refund claims	Filing deadlines vary by entry. Some may have already passed, while others remain open.

Quick Eligibility Checklist

Before diving into the filing process, ask yourself these questions.

• Did your company import goods between February 2025 and February 24, 2026?
• Were IEEPA duties assessed on those entries?
•  Was your company listed as the Importer of Record (IOR)?
• Do you have access to your CBP entry summaries and payment records?
• Were your imports assigned qualifying Chapter 99 Harmonized Tariff Schedule (HTS) codes?

If these conditions appear to apply to your entries, review your import records and current CBP guidance to determine whether your business may qualify for a refund.

Which IEEPA tariffs may qualify for refunds?

As mentioned, not every tariff paid during 2025 and early 2026 is eligible for a refund. The Supreme Court's ruling applies only to certain duties imposed under the International Emergency Economic Powers Act (IEEPA).

Potentially refundable duties include IEEPA-based tariffs collected under the drug-trafficking tariff programs involving Canada, Mexico and China, along with reciprocal IEEPA tariffs assessed on imports from other trading partners. Whether a particular payment can be recovered depends on the tariff code, entry date, liquidation status, Importer of Record and applicable CBP procedures.

The ruling does not affect duties imposed under other trade authorities, including:

• Section 232 tariffs on steel, aluminum and certain automobiles
• Section 301 tariffs on many imports from China
• Antidumping and countervailing duties (AD/CVD)
• Standard customs duties and other non-IEEPA tariffs

This distinction is one of the biggest sources of confusion among importers. Many headlines simply mention "tariff refunds," leading businesses to believe every duty they paid could now be recovered. In reality, refund eligibility depends on the legal authority used to impose the tariff — not simply when the duty was paid.

Why aren't refunds automatic?

If a bank mistakenly charges you a fee, you generally expect it to reverse the charge automatically. But customs doesn't work that way. Although the Court invalidated the tariffs, refunds are not automatic. Eligible importers must still demonstrate that qualifying duties were paid and follow the appropriate CBP refund process before those duties can be returned.

For companies with a handful of entries, that review may be relatively straightforward. Organizations importing hundreds or thousands of shipments often face a more complex task, requiring customs data, accounting records and entry documentation to be reconciled before every qualifying shipment can be identified.

How To Identify Qualifying Entries

One of the fastest ways to begin your review is by examining your CBP Form 7501 Entry Summary or your ACE Entry Summary Detail Report (ES-003). Look for Chapter 99 Harmonized Tariff Schedule (HTS) codes used to identify the IEEPA tariffs covered by the Supreme Court's ruling, including code families that begin with:

• 9903.01.xx
• 9903.02.xx

These codes provide a useful starting point, but they do not determine refund eligibility on their own. Each customs entry must still be reviewed based on the applicable tariff, entry details and current CBP guidance.

Looking for more information? Learn how tariffs affect imported goods in our guide, What Are Tariffs, or explore how Worldwide Express simplifies international logistics with our Cross-Border Shipping Services.

Confirm Your Eligibility Before Filing

After identifying potentially eligible IEEPA entries, the next step is determining whether your business can actually pursue a refund. Answering the following three questions can help you quickly assess your eligibility and focus your efforts on the entries most likely to qualify.

1. Are your entries still within the filing window?

Whether you can still recover qualifying IEEPA duties depends on where each customs entry stands in the import process. Most importantly, the filing window is generally tied to liquidation, which is the date of CBP's final determination of the duties owed for a shipment.

How the process works

Step	What happens
1. Goods enter the U.S.	The importer pays estimated duties based on the shipment information available at entry.
2. CBP reviews the entry	U.S. Customs and Border Protection verifies the classification, value, duties and other import requirements.
3. Entry is liquidated	CBP issues its final determination of the duties owed. Think of this as Customs' final bill for the shipment.
4. Filing window begins	Liquidation status helps determine which refund procedure may be available. Depending on the entry, an importer may be eligible to file through the current CAPE phase, file a protest within the applicable 180-day period or pursue another procedure identified by CBP.

Some businesses may have missed an available filing deadline for certain entries, while others remain eligible under current or upcoming CAPE phases. Because every entry follows its own timeline and may be subject to different procedures, importers should review their records and current CBP guidance promptly to determine which filing options remain available.

2. Was I the Importer of Record?

In most situations, the business seeking a refund must have been listed as the Importer of Record (IOR) on the customs entry. For some shipments, a carrier, customs broker or another party may have served as the Importer of Record and paid the duties to CBP. In those situations, that party may need to pursue the refund and determine how any recovered funds are returned to the customer that paid the tariff charge.

The Importer of Record is legally responsible for:

• Filing customs documentation
• Paying applicable duties
• Maintaining import records
• Ensuring customs compliance

If another company served as the Importer of Record, that company may control the refund process instead. Understanding this distinction early can prevent businesses from spending valuable time preparing documentation for entries they are not authorized to claim.

3. Do I have the proper documentation?

Even if you aren't ready to file today, gathering documentation now can make the process significantly easier.

Recommended documentation	Why it matters
CBP Form 7501 entry summaries	Confirms qualifying entries and Chapter 99 HTS codes
ACE reports	Helps identify affected shipments
Proof of duty payments	Supports refund calculations
Liquidation notices	Determines available filing options and deadlines
Importer of Record documentation	Confirms filing authority

Having these records organized also allows your customs broker to evaluate eligibility more efficiently if you decide to seek professional assistance. For businesses that imported through multiple ports, suppliers or customs brokers, organizing documentation now can also help identify qualifying entries that might otherwise be overlooked.

If you're navigating international shipping or customs for the first time, our Why International Shipments Get Stuck at Customs guide and Common Freight Terms & Definitions glossary provide additional insights to help you better understand the shipping process.

How much could you get back? Estimating your refund.

For many importers, the first question isn't how to file a refund claim — it's whether pursuing one is worth the effort. The answer starts with understanding how much your business paid in qualifying IEEPA duties. Companies with only a few affected entries may identify a modest recovery opportunity, while businesses that imported regularly throughout 2025 could discover substantial refundable duties spread across dozens or even hundreds of shipments.

A simple estimation approach

Creating a preliminary estimate doesn't require complex calculations. Start by identifying qualifying entries, then total the IEEPA duties associated with those shipments.

Step	What to do
1. Identify qualifying entries	Review your ACE reports and CBP Form 7501 entry summaries for qualifying IEEPA entries.
2. Total the IEEPA duties paid	Add the qualifying IEEPA duties assessed on those entries.
3. Estimate your refund opportunity	Use that total as a preliminary estimate before CBP review and any applicable adjustments.

This estimate won't necessarily match your final refund. Actual recoveries depend on factors such as the details of each customs entry, liquidation status and CBP's review of the claim. Even so, a preliminary estimate helps businesses understand the potential value of pursuing a refund and determine whether additional customs brokerage or legal assistance makes financial sense.

Recovering previously paid duties can also improve cash flow. Some businesses may use those funds to replenish inventory, invest in operations or offset rising transportation costs.

Recovering overpaid duties is only one piece of an effective import strategy. Learn how our Managed Transportation solutions[INT | /shipping-services/managed-transportation] help businesses simplify freight management, improve supply chain visibility, control transportation costs and coordinate domestic and international shipping through a single logistics partner.

Filing Through CAPE: CBP Refund Process Step by Step

If your entries qualify, filing through CBP's Consolidated Administration and Processing of Entries (CAPE) system may provide a streamlined administrative path for recovering qualifying IEEPA duties.

One reason so many businesses are still confused about tariff refunds is that the filing process is relatively new. Following the Supreme Court's decision, U.S. Customs and Border Protection introduced the CAPE system to streamline eligible refund requests.

Rather than requiring importers to navigate multiple filing methods, CAPE centralizes qualifying IEEPA refund claims within the ACE Portal.

What is CAPE?

CAPE is a CBP filing process established to facilitate qualifying IEEPA tariff refund requests.

CBP is implementing CAPE in multiple phases, with each phase expanding the categories of entries eligible for administrative refunds. Phase 1, which opened on April 20, 2026, covers certain unliquidated entries and certain entries within 80 days of liquidation. Phase 2 expanded eligibility to additional categories of entries, including certain reconciliation scenarios. CBP has announced that Phase 3 is expected to launch in late July 2026, expanding eligibility to additional liquidated entries and more complex refund claims.

Because eligibility varies by entry status and filing requirements, importers should review current CBP guidance or consult their customs broker before filing.

What does the filing process look like?

Although every importer's situation is different, the general process follows the same progression.

Step	What happens
1. Identify qualifying entries	Review ACE reports and entry summaries for eligible IEEPA duties.
2. Prepare documentation	Gather entry summaries, duty payment records and Importer of Record information.
3. Submit through CAPE	Upload qualifying entries through the ACE Portal.
4. CBP reviews the filing	CBP validates eligibility and recalculates duties after removing qualifying IEEPA charges.
5. Receive refund	Approved claims are generally paid as a consolidated refund rather than individual payments for each shipment.

Why accuracy matters

This is not simply an administrative exercise. Minor discrepancies between entry summaries, HTS classifications or Importer of Record information can delay processing or require corrections before a claim moves forward.
For importers with hundreds of entries, reviewing data before filing is often the most time-consuming part of the process. It's also one of the biggest reasons businesses rely on experienced customs brokers for assistance.

Official Government Resource

Looking for the latest refund guidance? Visit U.S. Customs and Border Protection's IEEPA Duty Refunds page for official eligibility requirements, filing instructions, CAPE updates, fact sheets and frequently asked questions.

Resource: CBP IEEPA Duty Refunds (cbp.gov)

Tariff Refund Frequently Asked Questions: Key Takeaways