Who is eligible for IEEPA tariff refunds?

U.S. importers of record who paid duties under IEEPA tariff programs -- including Liberation Day reciprocal tariffs and fentanyl-related tariffs on China, Canada, and Mexico -- are eligible. Refunds apply to entries from approximately April 2025 through February 24, 2026. You must be the importer of record with an ACE Portal account to receive refunds.

How much are the total IEEPA tariff refunds?

The total pool of IEEPA tariff refunds is approximately $166 billion, covering over 53 million import entries from 330,000 importers. Individual refund amounts depend on your import volume, tariff rates paid, and whether your entries are still within the eligible window.

When will tariff refunds be issued?

CBP told the Court of International Trade it needs 45 days from March 6, 2026 to build new refund functionality in its ACE system -- targeting approximately April 20, 2026. Automatic refunds for unliquidated entries may begin in mid-2026, while contested entries could take years. President Trump has said the full process could take up to 5 years.

Do I need to file a protest to get a tariff refund?

It depends on your entry status. Unliquidated entries should be automatically refunded once CBP builds its system. For entries already liquidated within the past 180 days, you should file a protest (CBP Form 19) to preserve your refund rights. Entries liquidated more than 180 days ago without a timely protest may not be eligible.

Are Section 122 tariffs eligible for refunds?

No. Only tariffs imposed under IEEPA are eligible for refunds following the Supreme Court ruling. Section 122 tariffs (the current 15% global surcharge), Section 232 (steel and aluminum), and Section 301 (China) tariffs remain in effect and are not subject to refunds.

Tariff Refunds for Small Businesses: What the CIT Ruling Means and How to Prepare

On March 4, 2026, the U.S. Court of International Trade (CIT) ordered Customs and Border Protection (CBP) to begin refunding tariff duties collected under IEEPA -- the tariffs the Supreme Court struck down on February 20. The numbers are staggering: $166 billion in duties across 53 million entries from 330,000 importers.

Two days later, the CIT suspended its own order after CBP declared it physically cannot process refunds at that scale with existing systems. The agency says it needs 45 days to build new functionality in its Automated Commercial Environment (ACE) portal.

If you're a small business that paid IEEPA tariffs, here's what you need to know right now.

Which Tariffs Qualify for Refunds?

Not all tariffs are eligible. Only duties imposed under IEEPA qualify:

Tariff Program	Authority	Refund Eligible?
"Liberation Day" reciprocal tariffs	IEEPA	Yes
Fentanyl tariffs (China, Canada, Mexico)	IEEPA	Yes
Section 122 global surcharge (15%)	Trade Act of 1974	No
Section 232 (steel & aluminum, 25%)	Trade Expansion Act	No
Section 301 (China, 7.5-25%)	Trade Act of 1974	No

Key distinction: If you're still paying tariffs today, those are under Section 122 or other authorities -- not IEEPA. The refunds apply to past IEEPA payments only.

The Two Tracks: Liquidated vs. Unliquidated Entries

The CIT's March 4 order creates two paths depending on the status of your import entries:

Unliquidated Entries

These are imports where CBP has not yet finalized the duty amount. CBP must reliquidate these entries without IEEPA duties. This is the simpler path -- no protest filing needed.

Liquidated Entries (Within 180 Days)

If your entry was already finalized (liquidated) but it's been fewer than 180 days since liquidation, the CIT ordered CBP to reliquidate and refund IEEPA duties. You may still need to file or have filed a protest to preserve your rights.

Liquidated Entries (Beyond 180 Days)

If liquidation happened more than 180 days ago and you didn't file a timely protest, your refund rights may be limited. Consult a customs broker or trade attorney immediately.

What CBP Is Building: The ACE Refund System

CBP told the court it's developing new ACE functionality to consolidate refunds by importer rather than issuing 53+ million individual refund checks. Key details:

Timeline: 45 days from March 6 (target: approximately April 20, 2026)
Method: Electronic ACH transfers only -- no paper checks
Requirement: You must have an active ACE Portal account
Consolidation: Multiple entries will be combined into a single refund per importer

Action Item: Set Up Your ACE Portal Account Now

If you don't already have an ACE Portal account, apply now at ACE Portal. The registration process can take several weeks, so don't wait until the refund system goes live.

Step-by-Step: What Small Businesses Should Do Now

1. Identify Your IEEPA Payments

Work with your customs broker to pull a report of all entries where you paid IEEPA-based duties. You're looking for entries between April 2025 (when Liberation Day tariffs took effect) and February 24, 2026 (when IEEPA tariffs were replaced by Section 122).

2. Gather Your Documentation

Compile these records for each affected shipment:

Entry summaries (CBP Form 7501)
Commercial invoices from your supplier
ACE reports showing duty amounts paid
Country-of-origin documentation
HTS classification records

3. Verify Your ACE Portal Access

4. Check Entry Liquidation Status

For each entry, determine whether it has been liquidated and when. This affects your refund pathway:

Not yet liquidated -- You should receive an automatic refund once the system is ready
Liquidated within 180 days -- Covered by the CIT order; file a protest if you haven't already
Liquidated beyond 180 days -- Consult legal counsel about your options

5. File Protests Where Necessary

For liquidated entries within the 180-day window, file protests through ACE or with your customs broker. The standard CBP Form 19 (Protest and Summons) is the mechanism.

6. Consider Legal Representation

If you're a larger importer with substantial refund amounts, consider joining one of the class-action-style cases at the CIT. Over 2,000 refund complaints were already filed before the March 4 ruling.

How Much Could You Get Back?

The total IEEPA refund pool is approximately $166 billion. Your individual refund depends on:

Volume of imports during the IEEPA tariff period (roughly April 2025 - February 2026)
Tariff rates paid (ranged from 10% to 50% depending on country and product)
Whether entries are eligible (liquidated within window or unliquidated)

Example: A small furniture importer bringing in $500,000/month from Vietnam during the IEEPA period paid a 46% tariff rate. Over 10 months, that's roughly $2.3 million in IEEPA duties potentially eligible for refund.

The Realistic Timeline

Despite the court order, experts warn the actual refund process will take time:

April 2026: CBP's new ACE refund system expected to go live
Mid-2026: First batch of automatic refunds for unliquidated entries
Late 2026 - 2027: Contested entries and protests begin processing
2027-2031: Complex cases, appeals, and class-action distributions continue

Trump himself has said the process could take up to 5 years. The proposed "Tariff Refund Act of 2026" in Congress would prioritize small businesses, but it hasn't passed yet.

Common Mistakes to Avoid

Assuming all tariffs qualify -- Only IEEPA tariffs are refundable. Section 232, Section 301, and Section 122 duties are not.
Missing the 180-day protest window -- If your entry was recently liquidated, you have a limited window to file a protest.
Not having ACE portal access -- Refunds will only be issued electronically through ACE.
Waiting to gather documentation -- Start pulling records now. The refund system will move faster for importers who have clean documentation ready.
Confusing importer of record -- Refunds go to the importer of record, not necessarily the party who bore the economic cost. If you bought goods from a domestic distributor who imported them, the refund goes to the distributor.

What About Consumers?

IEEPA tariff refunds go to importers of record -- the companies that paid the duties to CBP. Consumers who paid higher prices at retail do not receive direct refunds from CBP. Whether importers pass savings back to consumers is a business decision, not a legal requirement.

How TariffCenter.AI Can Help

Our AI-powered platform can help you:

Identify affected shipments using our HS code lookup and tariff rate tools
Calculate potential refund amounts based on your import history
Track the refund timeline as CBP builds its system
Navigate the documentation requirements with our guided workflows

Try our free HS Code Lookup tool to start identifying which of your products were subject to IEEPA tariffs.