US Importers · 2025–2026

Your IEEPA tariffs
are coming back.

On February 20, 2026, the Supreme Court struck down all tariffs imposed under IEEPA. On March 4, a federal court ordered CBP to refund every importer — not just those who sued. Here's exactly what you need to know and do.

Learning Resources v. Trump — 6-3 ruling, Feb 20 2026
$175B Total refund exposure
6–3 Supreme Court vote
1,000+ Cases already filed

Refund Calculator

Estimate your IEEPA tariff refund in 30 seconds

Estimated Refund Amount
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⚠ Estimate only Actual refund varies by HS code, liquidation status, and CBP processing. DOJ expected to appeal Mar 4 CIT order. Consult a licensed customs attorney.
Step 1 · ImmediateRegister for ACE account at cbp.gov — apply now, delays are severe
Step 2 · This WeekRun ES-003 report in ACE, identify all IEEPA-tariffed entries
Step 3 · RecommendedConsult customs attorney re: protective CIT filing — DOJ will likely appeal
Background

What happened, and why it matters

Action Plan

How to claim your IEEPA tariff refund

✓ Good news — no lawsuit required (for now) The CIT's March 4 order covers all importers automatically. However, because DOJ is expected to appeal, attorneys recommend taking proactive steps to lock in your rights.
⚠ Watch out for enforcement CBP is already seeing an exponential increase in CF-28 Requests for Information and CF-29 Notices of Action alongside refund processing. Any refund claim invites scrutiny of your import entries.
Immediate

Register for ACE Account

Apply for an Automated Commercial Environment (ACE) account at cbp.gov. This is your gateway to all import records and the mechanism for receiving electronic refunds. CBP is experiencing significant processing delays — apply today.

This Week

Pull Your Import Data

In ACE, run the Entry Summary Details Report (ES-003) and export to Excel. Identify every entry with IEEPA tariff charges between February 4, 2025 and February 24, 2026. This is the foundation of your claim.

This Week

Register for ACH Refund

Within ACE, register for Electronic ACH (Automated Clearing House) refund payments. This ensures CBP can deposit your refund directly to your bank account when the process opens. Requires an active ACE account.

Unliquidated Entries

File Post-Summary Corrections

For entries CBP has not yet liquidated: file a Post-Summary Correction (PSC) to remove the IEEPA duties. Must be filed within 300 days of entry date, or up to 15 days before scheduled liquidation — whichever is earlier.

Liquidated Entries

Consider a Protective CIT Filing

For already-liquidated entries, the broad CIT order should cover you — but because DOJ will likely appeal, many trade attorneys recommend filing a protective action in the CIT under §1581(i). Statute of limitations: generally 2 years from accrual.

Ongoing

Monitor CBP Implementation

CBP must develop refund procedures, but its system was "not designed for a mass refund." Watch for official CSMS notices. Processing may take months. The ACE system has also continued liquidating entries with IEEPA duties even after the Supreme Court ruling — monitor your entries actively.

Reference

Key dates & deadlines

ℹ New tariffs already in effect Trump imposed a new 10% global tariff under Section 122 of the Trade Act of 1974, effective February 24, 2026. These are NOT covered by the IEEPA refund ruling and are a separate legal authority.
Date Event Status Your Action
Feb 4, 2025 IEEPA refund window opens (fentanyl tariffs) Confirmed Include all entries from this date
Apr 2, 2025 Reciprocal tariff refund window opens Confirmed Include all entries from this date
Mar 7, 2025 USMCA-qualifying Canada/Mexico goods exempt from IEEPA Exception Exclude USMCA entries after this date
Feb 24, 2026 IEEPA refund window closes Confirmed Do not include entries after this date
Mar 4, 2026 CIT orders CBP to refund all importers In Progress Register ACE account immediately
TBD 2026 CBP begins processing refunds Awaiting Register for ACH refund in ACE
2 yrs from accrual CIT §1581(i) statute of limitations Don't Miss File protective CIT action early
FAQ

Frequently asked questions

Any US importer of record who paid IEEPA tariffs between February 4, 2025 and February 24, 2026 is potentially eligible. This includes importers from China, Canada, Mexico, and all other countries subject to IEEPA reciprocal tariffs. Note: goods from Canada and Mexico that qualified for USMCA duty-free treatment after March 7, 2025 are not eligible — those were already exempt from IEEPA. If you were the buyer but not the importer of record, you have no direct claim against CBP, but may have contractual claims against your supplier.
As of March 4, 2026, the Court of International Trade issued a broad order that covers all importers — not just those who filed suit. In theory, you may not need to do anything beyond having an ACE account to receive the refund. However, DOJ is expected to appeal this order. If the appeal succeeds, only importers with active CIT cases may be covered. This is why many trade attorneys recommend filing a protective action now.
Covered (eligible for refund): All IEEPA tariffs paid Feb 4, 2025 – Feb 24, 2026. This includes the 25% Canada/Mexico tariffs, the 10% China tariffs, and all reciprocal tariffs from Liberation Day (April 2, 2025).

NOT covered: Section 232 tariffs on steel and aluminum; Section 301 tariffs on China; the new Section 122 10% global tariff effective February 24, 2026. These were imposed under different legal authorities unaffected by the IEEPA ruling.
Nobody knows yet. CBP must design and implement a mass refund process it was never built for. Trade attorneys estimate processing could take several months at minimum — and could take longer if DOJ obtains a stay of the CIT's order. With $175 billion in potential refunds, this will be an unprecedented administrative undertaking. Don't expect a check soon.
ACE (Automated Commercial Environment) is CBP's online portal where all US import and export data is tracked. You need it to: access your complete import history, calculate the exact IEEPA duties you paid, and register to receive electronic ACH refund payments. Apply at cbp.gov. CBP is experiencing significant processing delays on new applications right now, so apply immediately.
Liquidated entries are still covered under the CIT's broad order. The court has confirmed its power to order "reliquidation" — reopening a closed entry to correct unlawfully collected duties. That said, because the CIT previously found that IEEPA duties are not protestable decisions, the traditional 180-day protest window may not apply. Consult a customs attorney about filing a CIT action under §1581(i) as an alternative route.
No firm deadline has been established yet. The statute of limitations for CIT actions under 28 U.S.C. §1581(i) is generally two years from when the cause of action accrued, but there is legal uncertainty about the exact accrual date in this context. Do not assume a specific deadline without consulting a licensed customs attorney. What is clear: filing sooner positions you better for early processing under whatever procedures the CIT establishes.

Stay ahead of the refund process

We track every CBP announcement, CIT order, and DOJ appeal. Get updates when it matters.

LEGAL DISCLAIMER This website provides general informational content only and does not constitute legal advice or create an attorney-client relationship. The IEEPA tariff refund process involves rapidly evolving legal and administrative developments. Information reflects available data as of March 5, 2026 and may not reflect subsequent court rulings, regulatory changes, or government actions. Consult a licensed customs attorney before taking any legal action. Refund estimates are approximations only — actual amounts depend on your specific HS codes, entry liquidation status, applicable exclusions, and CBP processing.