IEEPA Tariff Refund FAQ

Any importer of record who paid tariffs imposed under the International Emergency Economic Powers Act (IEEPA) on goods entered between February 4, 2025 and February 20, 2026 is potentially eligible. This includes duties collected under HTS Chapter 99 subheading 9903.01 codes covering China, Hong Kong, Canada, Mexico, and the 50+ countries subject to reciprocal tariffs.

Yes. Eligibility is not limited to large companies. Anyone who was the importer of record and paid IEEPA duties — including small businesses, sole proprietors, and individuals importing commercial quantities — can file for a refund. If you used a customs broker, ask them for your entry summary data to verify whether IEEPA duties were assessed.

It depends on who was the importer of record on the entry summary. If you were the IOR, you can file. If the fulfillment center or a third party was the IOR, they would need to file the claim. Check your entry documentation or ask your customs broker.

Yes, but only for the IEEPA portion of duties. China imports were subject to both Section 301 tariffs (from 2018-2019, still in force) and IEEPA tariffs (the additional tariffs added starting Feb 4, 2025 that reached up to 145%). You can only recover the IEEPA portion. The Section 301 tariffs remain valid and are not refundable.

USMCA-qualifying goods from Canada and Mexico were exempt from IEEPA tariffs starting March 7, 2025. If your goods qualified under USMCA and you claimed the preference at entry, no IEEPA duty was charged, so there is nothing to refund. If you did not claim USMCA at entry, you may file a 1520(d) claim within 1 year of importation to retroactively claim the preference.

The process depends on whether your customs entry has been liquidated. For unliquidated entries, file a Post-Summary Correction (PSC) through CBP's ACE portal to remove the IEEPA duty lines. For entries that have already been liquidated, file a formal protest using CBP Form 19 through the ACE protest module within 180 days of liquidation. Reference the Supreme Court ruling of February 20, 2026 as the legal basis.

A PSC is a mechanism to correct an entry summary after it has been filed but before it is liquidated. For IEEPA refund purposes, you would file a PSC to remove the Chapter 99 IEEPA duty lines from your original entry. This is the fastest and simplest path to a refund. PSCs are filed electronically through the ACE portal.

CBP Form 19 is the formal protest mechanism used to challenge customs decisions — including duty assessments — after an entry has been liquidated. For IEEPA refunds, you would protest the inclusion of IEEPA duties, citing the Supreme Court ruling. Protests must be filed within 180 days of the liquidation date and are submitted through the ACE protest module.

For PSCs, most customs brokers can handle the filing as part of their normal service. For protests, while you can file yourself, many importers use a customs broker or trade attorney, especially for large refund amounts. For Court of International Trade proceedings, you will need an attorney admitted to practice before the CIT.

PSCs are filed per entry. However, for protests, CBP allows you to combine multiple entries in a single protest as long as they involve the same port, the same category of merchandise, and the same issue. This can be more efficient if you have many affected entries.

For unliquidated entries, file a PSC as soon as possible — entries typically liquidate about 314 days after the entry date. For liquidated entries, you have 180 days from the liquidation date to file a protest. If your protest is denied, you then have 180 days to file suit in the Court of International Trade. Act promptly: some early IEEPA entries from February 2025 may already be approaching liquidation.

Processing times vary. PSC refunds can be processed in 30-90 days after the corrected entry liquidates. Protest refunds typically take 6-12 months, though CBP may expedite IEEPA protests given the Supreme Court ruling. If you request accelerated disposition on your protest, CBP must respond within 30 days.

If your entry is approaching the 314-day liquidation window, file a PSC immediately. You can also request a suspension or extension of liquidation through your customs broker or trade attorney. Once an entry liquidates, you lose the PSC option and must use the more complex protest process.

The Supreme Court struck down all tariffs imposed under the International Emergency Economic Powers Act (IEEPA). This includes: China/Hong Kong IEEPA tariffs (up to 145%), Canada IEEPA tariffs (25%), Mexico IEEPA tariffs (25%), and reciprocal tariffs on 50+ countries (10-49%). All of these used Chapter 99 subheading 9903.01 HTS codes.

No. Section 301 tariffs (the original China trade war tariffs from 2018-2019 under Lists 1-4) were imposed under a different legal authority and were not part of the Supreme Court ruling. These tariffs remain in full force. Only the additional IEEPA tariffs added starting February 2025 are refundable.

No. Section 232 tariffs on steel, aluminum, automobiles, copper, and timber were imposed under the Trade Expansion Act of 1962, not IEEPA. They are unaffected by the Supreme Court ruling and remain in force.

After the Supreme Court ruling, President Trump signed a 15% global tariff under Section 122 of the Trade Act of 1974, effective February 24, 2026. This is a separate, new tariff and does not affect your IEEPA refund eligibility. The IEEPA duties you already paid are still refundable regardless of the Section 122 replacement. Note: Section 122 tariffs automatically expire after 150 days (~July 24, 2026).

Your refund equals the total IEEPA duties paid, plus any merchandise processing fees attributable to the IEEPA portion, plus interest from the date of payment. To find this amount, review your entry summaries for Chapter 99 duty lines with 9903.01 codes. Your customs broker can pull this data from ACE. Use our refund calculator at vatcheck.io/refunds for an estimate.

Yes. Under 19 USC § 1505(c), CBP must pay interest on refunded duties. Interest accrues from the date the duties were deposited to the date of the refund. The interest rate is set quarterly by the IRS and is currently tied to the federal short-term rate plus 2 percentage points.