USA IEEPA Tariff Refunds in 2026
For U.S. importers, the tariff landscape in 2026 has changed dramatically.
After the U.S. Supreme Court ruled in February 2026 that the Trump administration exceeded its authority when it used the International Emergency Economic Powers Act (IEEPA) to impose broad tariffs, attention quickly shifted from tariff collection to something equally important for businesses: refunds.
Billions of dollars in tariff payments are now being returned to importers. According to recent court filings reported by major U.S. news organizations, U.S. Customs and Border Protection (CBP) has processed and certified approximately $100 billion in refunds as of early August.
But the refund process is not as simple as receiving an automatic check.
For companies that imported goods into the United States during the period when IEEPA tariffs were collected, understanding entry status, liquidation, refund procedures and documentation is becoming increasingly important.
What Are IEEPA Tariffs?
The International Emergency Economic Powers Act, commonly known as IEEPA, is a U.S. federal law enacted in 1977.
The law gives the President broad powers to respond to certain declared national emergencies involving threats originating outside the United States.
In 2025, the Trump administration relied on IEEPA to impose several categories of tariffs on imported merchandise, including broad country-based and reciprocal tariffs.
The legal authority behind those tariffs was subsequently challenged by businesses, importers and other parties.
The dispute eventually reached the U.S. Supreme Court.
In February 2026, the Supreme Court ruled against the administration’s use of IEEPA as authority for the challenged tariffs. The decision triggered a massive administrative and legal process concerning duties that had already been collected from U.S. importers.
It is important to note that not every U.S. tariff was invalidated by this decision.
Tariffs imposed under other legal authorities, including certain Section 232 and Section 301 measures, are separate issues and should not automatically be treated as refundable IEEPA duties.
How Large Is the IEEPA Refund Program?
The scale of the refund program is unprecedented.
According to recent reporting, the U.S. government has already processed approximately $100 billion in IEEPA tariff refunds. Major companies have received very substantial amounts, illustrating the financial significance of the program for large importers.
The total potential exposure has been estimated even higher because the government collected IEEPA-related duties from a very large number of import transactions.
The important point for smaller and mid-sized importers is this:
The refund opportunity is not limited to large corporations.
Companies that paid qualifying IEEPA duties should review their own customs records rather than assuming the refund process only applies to major multinational importers.
Does Every Importer Automatically Receive a Refund?
No.
This is one of the most important points for U.S. importers to understand.
CBP has established the CAPE — Automated Commercial Environment (ACE) processing system to facilitate the refund of eligible IEEPA duties, including associated interest. CBP describes CAPE as a system designed to consolidate eligible refunds rather than handling every refund as a completely separate entry-by-entry transaction.
However, the legal status of an import entry can affect the way a refund is obtained.
The situation becomes particularly complicated when an entry has already gone through the customs process and has become finally liquidated.
Recent litigation has focused heavily on whether importers that did not participate in the underlying lawsuits should automatically receive refunds for such entries.
In August 2026, the U.S. government was still challenging a Court of International Trade order that would require refunds for all affected importers, including companies that were not parties to the litigation.
That means the legal and administrative pathway can differ depending on the status of the importer’s entries.
What Is the Difference Between Liquidated and Unliquidated Entries?
For importers, this distinction is extremely important.
Unliquidated Entries
An entry that has not yet been finally liquidated may remain within the administrative refund process.
These entries can generally be handled through the mechanisms established by CBP for eligible IEEPA refunds.
Finally Liquidated Entries
Once an entry has been finally liquidated, the administrative options can become more complicated.
Recent Court of International Trade proceedings have addressed refund claims involving finally liquidated entries. Some importers that brought individual cases have obtained court-ordered paths to recover qualifying IEEPA duties.
This is why companies should not simply look at the amount of tariff they paid.
They should also determine:
- Which entries were affected
- When those entries were filed
- Whether they have been liquidated
- Whether they are finally liquidated
- Whether a protest was filed
- Whether the importer has already received a refund
- Whether additional legal or administrative action may be necessary
How Can U.S. Importers Check Their Potential Refund?
The first step is to build an accurate record of potentially affected entries.
We recommend reviewing the following information:
1. Import Entry Numbers
Identify the customs entries that were subject to the IEEPA duties.
2. IEEPA Duty Amount
Determine exactly how much IEEPA duty was paid on each qualifying entry.
3. Entry Date
Check when the merchandise entered the United States.
4. Liquidation Status
Determine whether each entry is:
- Unliquidated
- Liquidated
- Finally liquidated
5. Customs Broker Records
Ask your customs broker for entry summaries, payment records and relevant ACE information.
6. Refund Status
Check whether CBP has already processed a refund associated with the entry.
This documentation can help an importer distinguish between a refund that is already being processed and one that may require additional action.
How Does CBP’s CAPE System Work?
CBP’s current refund framework uses the CAPE system within the ACE environment.
The objective is to streamline the processing of eligible IEEPA refunds and associated interest.
CBP currently advises that valid IEEPA refunds are generally expected to be issued within approximately 60–90 days after acceptance of the CAPE submission, although actual timing can depend on the circumstances of the claim.
For importers, this means the process should be treated as an operational customs project rather than simply waiting for money to arrive.
Companies should coordinate with their:
- Customs broker
- Import compliance team
- Finance department
- Trade counsel, where appropriate
to make sure eligible entries are properly identified and supported.
What About Importers That Have Already Received a Refund?
Receiving one refund does not necessarily mean the entire review is complete.
A company may have imported hundreds or thousands of shipments during the relevant period.
Some entries may already have been refunded while others may still be pending because of differences in:
- Entry status
- Liquidation
- Filing history
- Processing stage
- Customs data
- Legal status
For this reason, importers should reconcile refunds against their original duty payments.
A simple internal reconciliation can include:
| Item | Information to Review |
|---|---|
| Entry Number | Original customs entry |
| Import Date | Date of entry |
| IEEPA Duty | Amount originally paid |
| Entry Status | Liquidated / Unliquidated |
| Refund Amount | Amount received |
| Refund Date | Date received |
| Interest | Whether applicable |
| Outstanding Balance | Amount still under review |
This can help prevent companies from overlooking eligible amounts.
What Happens If the Importer Has Not Received a Refund?
This is where the situation becomes more complicated.
The current legal dispute includes questions about the rights of importers whose entries have already been finalized and whether CBP must automatically refund all affected importers.
The government has argued that the Court of International Trade’s broad refund order exceeds the court’s authority, while the court has issued orders supporting refund relief in certain circumstances.
Therefore, importers should not assume that doing nothing will necessarily result in an automatic refund.
For companies with significant potential refunds, professional customs or legal advice may be appropriate.
The applicable process can depend on the specific entry history and legal status of the importer.
What Documents Should Importers Keep?
Companies should maintain a complete audit trail.
At minimum, we recommend retaining:
- Commercial invoices
- Packing lists
- Bills of lading
- Entry summaries
- Customs payment records
- HTS classification information
- Country-of-origin documentation
- Broker statements
- IEEPA duty calculations
- ACE-related records
- Refund notifications
- Correspondence with CBP or customs brokers
Good documentation is particularly important because the refund process is connected to individual customs entries and the underlying duty payments.
Don’t Confuse IEEPA Refunds With Other Tariff Programs
Another important issue is tariff classification.
A refund of an IEEPA duty does not automatically eliminate other duties applicable to the same shipment.
For example, an imported product may potentially involve:
- Normal Column 1 duty
- Section 301 duties
- Section 232 duties
- Anti-dumping or countervailing duties
- Merchandise Processing Fee (MPF)
- Harbor Maintenance Fee (HMF)
- Other applicable customs charges
Therefore, importers should review the complete entry rather than simply calculating:
IEEPA duty paid = total refund
The actual refund amount can depend on the specific tariff provisions and entry circumstances.
What Should U.S. Importers Do Now?
For companies that imported significant volumes during the IEEPA tariff period, we recommend taking five practical steps.
Step 1: Identify Potentially Affected Entries
Work with your customs broker to generate a list of entries that included IEEPA duties.
Step 2: Calculate the Total Amount Paid
Determine the actual IEEPA duty amount associated with those entries.
Step 3: Review Liquidation Status
Separate unliquidated entries from liquidated and finally liquidated entries.
Step 4: Reconcile CBP Refunds
Compare refunds received against the original amounts paid.
Step 5: Escalate Unresolved Claims
If significant amounts remain outstanding, discuss the appropriate administrative or legal options with your customs broker and qualified trade counsel.
Why This Matters for Importers in 2026
The IEEPA refund issue is more than a legal story.
For many U.S. businesses, it represents a potentially significant cash-flow opportunity.
A company that paid hundreds of thousands or millions of dollars in IEEPA duties could potentially recover a substantial amount of previously paid customs duties.
At the same time, the refund process highlights a broader lesson for importers:
Customs compliance does not end when cargo is delivered.
Importers need to maintain accurate records throughout the entire customs lifecycle — from product classification and country of origin to entry filing, duty payment, liquidation and potential post-entry recovery.
And with U.S. trade policy continuing to evolve, companies should expect further changes in the way tariffs are imposed and administered.
