IEEPA Tariff Refunds
How to Prepare in the Right Way

In 2026, a court ruling struck down IEEPA tariffs, giving importers a path to recover duties paid in 2025-understand what it means, who qualifies, and how to claim refunds before key deadlines expire.

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    IEEPA Tariffs Invalidated
    Refunds Exceed $170+ Billion

    Following the Supreme Court’s February 20, 2026 ruling on IEEPA tariffs, US importers are eligible to recover previously paid duties.

    • 170+ Billion

      IEEPA duties collected by US Customs

    • 300,000 + Importers

      Impacted by IEEPA Tariffs

    • 50+ Million

      Total entries subject to IEEPA Tariffs

    Tariff Refund Progress and Timing Update

    • 1

       Feb 2025, the federal government imposed tariffs on certain imports under the IEEPA. These surcharges applied broadly across a range of goods and countries.  

    • 2

      May 2025, the U.S. Court of International Trade ruled that IEEPA tariffs exceeded the President’s statutory authority, declaring them unlawful.

    • 3

      August 2025, the Federal Circuit Court of Appeals reviewed the case, issuing mixed opinions on the scope of the President’s authority under IEEPA.

    • 4

      February 20, 2026, the U.S. Supreme Court, in a 6–3 decision in Learning Resources, Inc. v. Trump, ruled that IEEPA tariffs are unconstitutional, striking them down.

    • 5

      In March 2026, the U.S. Court of International Trade (“CIT”) ruled that these IEEPA‑based tariffs were unlawful.
       
      -That ruling means importers who paid those duties can now claim tariff refunds from U.S. Customs and Border Protection (CBP)

      -The refund process is straightforward from a legal perspective, but the route you take depends on the status of each import entry in CBP’s system. 

    Ready to See If You Qualify?

    If your business paid IEEPA‑related duties in 2025, don’t wait to find out if you can recover those funds. Our trade consultants can review your import data quickly and tell you exactly which entries may be refundable.

    Let’s explore your situation arrow_outward arrow_outward

    Determine the Status of Your Entries

    Recent court orders also allow re-liquidation, meaning that finalized entries may now be reopened and reviewed again, giving importers the opportunity to reassess and potentially recover certain IEEPA related duties that were previously considered closed.

    • More_Up
      Entry Filing

      Importers file a customs declaration with CBP detailing goods, value, and duties owed when products enter the U.S.

    • Checklist
      CBP Review Period

      CBP typically has up to 314 days to review and “liquidate” the entry, finalizing the duties and account.

    • Edit
      Unliquidated Entries

      If the entry is still open, importers can make changes by submitting a Post-Summary Correction (PSC).

    • Timer
      Liquidated Entries

      Once finalized, importers must file a protest within 180 days to claim refunds, though some entries may be reopened under recent IEEPA rulings.

    Refund Path by Entry Status

    Entry StatusWhat it MeansRefund Path
    UnliquidatedCBP has not finalized the duty amountSubmit a Post-Summary Correction (PSC) via the ACE portal – usually the fastest path to recovery
    LiquidatedDuties are finalized; books closedFile a formal CBP protest within 180 days of liquidation; recent rulings may allow some exceptions
    Finalized / Older EntriesUsually beyond the protest windowCertain entries may still qualify for reliquidation under March 2026 CIT rulings

    Prepare the Essential Documents

    To successfully claim IEEPA tariff refund, importers must gather the right documentation, verify applicable tariff codes, and ensure proper system access. Preparing these essentials in advance helps streamline the process and avoid delays.
    Approval_Delegation

    Documentation & Records

    Gather all required entry documents, including CBP Form 7501 and proof of duty payments. These records establish what was paid and form the foundation of your refund claim.

      Assignment

      Tariff Verification

      Identify and confirm the specific IEEPA tariff codes applied to your entries. Accurate classification is critical to ensure eligibility and avoid delays in processing your refund.

        Edit_Document

        CBP’s ACE portal

        Ensure access to CBP’s ACE portal and enrollment in ACH for electronic refunds. Working with an experienced customs broker or specialist can streamline the process and reduce errors.

          How Leyton Can Help

            Eligibility Assessment

            Identify which of your import entries qualify for refunds under the IEEPA ruling by analyzing tariff codes, entry status, and payment history to ensure no eligible refunds are overlooked.

            Process Navigation

            Determine the correct path—whether through Post-Summary Corrections (PSC), formal protests, or re-liquidation-and manage each step efficiently to meet strict CBP deadlines.

            Documentation & Data Management

            Collect, organize, and validate all required entry documents, payment records, and supporting data to build a complete and accurate refund claim.

            Regulatory Compliance

            Ensure full compliance with U.S. customs laws and trade regulations throughout the refund process, minimizing risk and avoiding costly errors or delays.

            Maximized Refund Recovery

            Strategically manage your claims to recover the full amount of eligible refunds as quickly and accurately as possible, including any applicable interest.

          Our Team Lead

          Leyton helps businesses navigate IEEPA tariffs with support from experienced lawyers and trade experts. We assess import and export activities, manage compliance and documentation, and work with authorities to help reduce tariff exposure and operational burden.

          IEEPA Tariff Refund

          Jean-Daniel VERMETTE

          SR Custom Duty Manager

          FAQs

          Can’t find the answer you’re after?

          Contact Our Team

          What are IEEPA tariffs? keyboard_arrow_down keyboard_arrow_up

          In 2025, the U.S. imposed tariffs under the International Emergency Economic Powers Act (IEEPA) on certain imported goods. In February 2026, the Supreme Court ruled these tariffs unconstitutional, and the U.S. Court of International Trade confirmed in March 2026 that importers who paid these tariffs may now be eligible for refunds — plus interest. 

          Can we just do this ourselves or through our customs broker? keyboard_arrow_down keyboard_arrow_up

          You could, but the process is complex and procedural

          -ACE portal setup  
          -ACH banking for electronic refunds  
          -Post-Summary Corrections (PSC) or formal protests  
          -Historical entry audits and tariff verification  

          Leyton’s value: We do not compete with your broker. Instead, we optimize what you already do, adding an extra layer of review, accuracy, and speed — and we handle everything end-to-end. 

          What documentation is required? keyboard_arrow_down keyboard_arrow_up

          To successfully claim refunds, importers must provide: 

          -CBP Form 7501 for each entry  
          -Proof of duty payments  
          -Records confirming product classification and applicable tariff codes  
          -Access to the ACE portal and enrollment in ACH for electronic refunds  

          Leyton helps gather, organize, and validate all documents to minimize errors and ensure smooth processing. 

          What is the timeline for recovery? keyboard_arrow_down keyboard_arrow_up

          Unliquidated entries: Can be corrected immediately via PSC. Refunds typically issued quickly once submitted.  

          Liquidated entries: Must protest within 180 days of liquidation.  

          Older entries: Some may be eligible for reliquidation, but speed is still critical to maximize recovery.  

          How are refunds issued? keyboard_arrow_down keyboard_arrow_up

          All IEEPA refunds are issued electronically through ACH into the importer of record’s bank account. Paper checks are not used. Correct ACH setup in the ACE portal is mandatory.

          What if we don’t know which entries qualify? keyboard_arrow_down keyboard_arrow_up

          Leyton’s consultants review your import data to: 

          -Identify unliquidated, liquidated, and finalized entries  
          -Verify tariff codes and payment amounts  
          -Determine the fastest and most compliant refund path  

          This ensures no eligible refunds are overlooked.

          Is this risky or costly? keyboard_arrow_down keyboard_arrow_up

          No risk: Leyton works on a success-based model — you pay only if we recover funds.  

          Compliance guaranteed: All filings are handled according to CBP regulations, avoiding mistakes that could delay or disqualify claims.  

          Minimal internal effort: We handle all documentation, filings, and CBP follow-up.  

          How long does the process take? keyboard_arrow_down keyboard_arrow_up

          -The timeline depends on the entry status and CBP review.  

          -Unliquidated entries are usually resolved fastest.  

          -Liquidated entries take longer due to formal protest processing.
           
          -Leyton manages deadlines carefully to ensure no opportunities are missed.  

          How does Leyton add value? keyboard_arrow_down keyboard_arrow_up

          End-to-end management: Eligibility analysis, documentation, filing, follow-up  

          Compliance-first approach: Avoid errors and delays with CBP  

          Optimizing what you already do: We work alongside your broker without disrupting your current processes  

          Success-based billing: You pay only if refunds are recovered  

          Maximized recovery: We ensure you recover the full amount of eligible duties plus interest  

          Ready to See If You Qualify?

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