There are practical steps importers can take now to prepare for potential IEEPA tariff refunds. Use this guide to understand eligibility and navigate the refund process.
The U.S. Supreme Court’s recent decision striking down the tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has opened the door for many U.S. small businesses and importers to seek refunds. However, determining whether your business qualifies—and understanding what steps to take next—can be challenging.
As the refund process is constructed, this guide provides information to help businesses identify whether they paid IEEPA based tariffs, understand what types of duties may be eligible for refunds, and prepare for the emerging refund process.
In this article:
- The latest updates on the IEEPA refund process
- Step-by-step guide for importers to receive refunds and what to do right now
- Questions to discuss with your customs broker or trade counsel
The Latest: Customs and Border Protection (CBP) has started to release details for a refund process. This agency—which collects all U.S. tariffs and will be responsible for refunding all the IEEPA tariffs collected—expects to launch the system on or around April 20, 2026. Refunds are only available for tariffs applied under IEEPA.
The tariff refund system will distribute refunds to importers through a CBP online, automated system. Importers can take practical steps now to be ready if refunds become available.
4 Things Importers Can Do Now to Prepare for Potential Tariff Refunds
1. Update Importer Record Info
Make sure your CBP importer record (Form 5106) for your company is up-to-date and includes an email address that is not your broker’s email (required for authentication).
Note: Licensed custom brokers have access to the ACE Secure Data Portal and can update Form 5106.
2. Create an ACE Portal Account
Create an account in CBP’s Automated Commercial Environment Secure Data Portal (ACE Portal). This will enable your company to run reports and download entry data to show IEEPA tariff payments for which your company may seek refunds.
Note: Some importers have reported new ACE account setup takes 3-4 weeks.
3. Enroll in ACH Refund
Sign up for Automated Clearinghouse (ACH) Refund. CBP requires ACH enrollment to receive duty refunds electronically. After enrolling for ACH refunds, any refund you receive will automatically be deposited directly into your bank account. Companies may wish to consult with their customs broker or trade counsel.
4. Identify Exceptions
Determine whether all of your IEEPA entries will be covered in the system's initial rollout, or whether you have entries that are within the two exceptions identified below. If you have entries that fall within the two exceptions, you should consult with your customs broker and lawyer to evaluate whether further action is needed to preserve your right to a refund.
Enroll Now - Refunds Are Fully Electronic
Importers need to sign up for Automated Clearinghouse (ACH) Refund. ACH enrollment is required to receive refunds electronically and automatically deposited into your bank account. Reports indicate few importers have taken this step: Act now to be ready when the refund process is formally launched.
Refund Process Updates
- After the Supreme Court’s Feb. 20 decision on IEEPA, the U.S. Court of International Trade (CIT) ordered the government to take immediate action on refunds.
- On March 6, Customs and Border Protection (CBP) submitted a plan for an expedited and simplified tariff refund system to the CIT. CBP indicated it would be able to create and launch the tariff refund system within 45 days (by around April 20).
- On March 12, CBP released new details of a 4-step refund system. Those steps are detailed above.
The U.S. Chamber welcomed the CBP proposal, and we expect to learn more from the administration in the days ahead.
Two Exceptions to IEEPA Tariff Refunds
The system will not immediately apply to all IEEPA entries. There are two exceptions:
1. Liquidated Entries
When the system first launches, it will only apply to unliquidated entries and entries within the 90-day voluntary reliquidation period. CBP plans to expand the system to cover entries for which liquidation has become final, but it has not specified a date by which it will do so.
2. Other Exceptions
CBP has stated that the following categories of entries subject to IEEPA duties will not be processed through this system, at least initially:
- Entries that have been flagged for reconciliation, as well as Entry Type 09;
- Entries designated on a drawback claim;
- Entries covered by an open protest;
- Entries not filed in ACE, and entries without a liquidation status is ACE; and
- Entries subject to AD/CVD, for which DOC has issued liquidation instructions, that are pending liquidation.
Bottom Line: Your customs broker can help you evaluate the liquidation status of your entries and whether any of your entries fall into these categories.
Watch: What the Supreme Court Decision Means for Small Business