8 Signs Your Company Is Eligible for an IEEPA Tariff Refund

Here’s a question we hear every day: “Am I eligible for an IEEPA tariff refund?” The short answer is that if you imported physical goods into the United States between February 2025 and February 2026, there’s a strong chance you are. But “strong chance” isn’t good enough when $166 billion in refunds is on the table. You need to know for sure.

The Supreme Court’s February 2026 ruling in Learning Resources, Inc. v. Trump struck down all IEEPA tariffs as unconstitutional. That means every dollar collected under IEEPA authority during the affected period is owed back to the importers who paid it. But not every importer realizes they paid IEEPA-specific tariffs, and not every company that thinks it’s eligible actually is.

Below are eight signs that strongly indicate your company has an IEEPA tariff refund claim. If even one of these applies to you, it’s worth investigating further. If three or more apply, you almost certainly have a claim worth filing. Our eligibility guide covers the formal requirements, but this is the quick self-assessment.

Sign 1: You Import Physical Goods Into the United States

This is the baseline requirement. IEEPA tariffs were duties on imported goods — physical products entering U.S. customs territory. If your company imports anything tangible from outside the United States, you’re in the eligible universe.

It doesn’t matter what you import. Electronics, auto parts, clothing, furniture, raw materials, machinery, food products, toys, chemicals — IEEPA tariffs applied broadly across product categories. The tariffs weren’t targeted at specific industries; they were applied at the country level, meaning virtually every product from affected countries was hit.

Who this doesn’t cover

• Service companies that don’t import physical goods (software, consulting, etc.)
• Domestic-only manufacturers using exclusively U.S.-sourced materials
• Companies that buy imported goods domestically (you bought from a U.S. distributor who was the actual importer of record)

That last point is important. The refund goes to the Importer of Record (IOR) — the entity listed on the customs entry. If you buy imported goods from a U.S. wholesaler, they were the IOR, and they’re the ones with the refund claim. You may have absorbed the tariff cost through higher prices, but you don’t have a direct refund claim.

However, if you import directly — even through a customs broker or freight forwarder who files entries on your behalf — you’re likely the IOR and have a direct claim.

Sign 2: You Imported Between February 2025 and February 2026

IEEPA tariffs were in effect during a specific window:

If your company had active import operations during any part of this window, the entries filed during that period may include IEEPA duties. The more months you were actively importing, the larger your potential claim.

Even if you only imported during part of the window, your claim could be significant. A company that imported $5 million in goods from China during a three-month period at a 20% IEEPA surcharge has a potential claim of $1 million — just from that narrow window.

The complete guide to IEEPA tariff refunds covers the full timeline and how each tariff action maps to the refund process.

Sign 3: Your Goods Came From China, Canada, Mexico, or Reciprocal Tariff Countries

IEEPA tariffs applied to imports from specific countries, but the list of affected countries was broad. Here’s the breakdown:

Highest exposure:

• China — 20% IEEPA surcharge on top of existing Section 301 tariffs, plus fentanyl-related duties
• Canada — 25% (10% on energy products)
• Mexico — 25%

Reciprocal tariff countries (April 2025 onward):

• Rates ranging from 10% to 145% depending on the country
• Applied to virtually every country with a trade surplus with the U.S.
• Even the baseline “universal” rate was 10% on imports from most countries

If your supply chain touches any of these countries — and with today’s global supply chains, most do — you probably have IEEPA tariff exposure.

Some importers are surprised to learn they have claims on imports from countries they didn’t expect. The reciprocal tariffs cast an extremely wide net. If you imported from the EU, Japan, South Korea, Vietnam, India, Taiwan, or dozens of other countries after April 9, 2025, those entries likely include IEEPA duties.

Get your free Impact Assessment →

Sign 4: You Saw Tariff Rate Increases in 2025

This is the “smell test” sign. If your per-unit duty costs increased in 2025 compared to 2024, there’s a good chance the increase was due to IEEPA tariffs.

Think about it this way: if you were paying 6.5% MFN duty on a product from a certain country in 2024, and suddenly you were paying 16.5% or 31.5% in 2025 on the same product from the same country, the increase was almost certainly an IEEPA tariff. That incremental amount — the difference between your 2024 rate and your 2025 rate — is what you can claim as a refund.

How to check

Pull your entry summaries from early 2025 and compare duty rates to entries from late 2024 for the same products. If you see rate jumps, look at the HTS codes. If the entries include codes under heading 9903.01 or 9903.02, those are IEEPA duties.

Your accounts payable records may also tell the story. If your total customs duty payments spiked in Q1 or Q2 2025 without a corresponding increase in import volume, IEEPA tariffs are the likely cause.

The refund amount calculator helps you separate IEEPA duties from other duty types so you can quantify exactly how much of your 2025 increase is refundable.

Sign 5: Your Customs Broker Mentioned IEEPA or Chapter 99 Duties

If your customs broker flagged IEEPA tariffs, Chapter 99 duties, or HTS heading 9903 at any point in 2025, pay attention. Brokers classify entries and apply duty codes — they saw the IEEPA tariffs on your entries in real time.

Some brokers have already been proactive about contacting clients regarding IEEPA refunds. If yours has, respond to them. If they haven’t, call them and ask specifically about IEEPA exposure across your entry portfolio.

The key codes to ask about:

• HTS 9903.01.xx — China-specific IEEPA tariffs and fentanyl tariffs
• HTS 9903.02.xx — Reciprocal tariffs (including Canada and Mexico)

Your broker should be able to pull a report showing all entries with these codes and the total duties paid under them. This report is the starting point for your claim. If your broker isn’t familiar with the IEEPA refund process, our 7-step filing guide provides the framework.

Sign 6: Your Cost of Goods Sold (COGS) Increased Due to Tariffs

If your finance team traced COGS increases to tariff costs in 2025, you have a clear trail back to IEEPA duties. Many companies absorbed tariff increases into COGS rather than passing them to customers — and that absorbed cost is now refundable.

Here’s what that looks like on your P&L:

That $20 per unit IEEPA surcharge, multiplied across every unit you imported during the affected period, is your refund claim. If your annual import volume was 50,000 units, that’s a $1 million claim just from the IEEPA component.

The before vs. after import cost analysis shows how the refund flows through your financial statements and what it means for margins going forward.

Sign 7: You Have an ACE Portal Account

The Automated Commercial Environment (ACE) portal is CBP’s electronic system for trade data. If your company has an ACE portal account — which most active importers do — you have direct access to the entry data you need to file a claim.

Having an ACE account means:

• You’re an active importer of record
• You can pull your own ES-003 reports
• You can verify entry-level details, duty amounts, and liquidation status
• You can authorize your broker or representative to file on your behalf

If you have ACE access but haven’t logged in recently, do it now. Verify your credentials, make sure your account is active, and pull your ES-003 report for the IEEPA tariff period. That single report contains everything you need to assess your eligibility and estimate your claim value.

Don’t have ACE access? Your customs broker does, and they can pull the reports on your behalf. But consider setting up your own access for future reference — it gives you direct visibility into your entry data and filing status.

Sign 8: Your Competitors Are Already Filing

This is less a sign of eligibility and more a sign that you should act now. If companies in your industry are already filing IEEPA tariff refund claims or preparing for CAPE, and you’re not, you’re falling behind in two important ways.

First, queue position matters. CBP is processing claims sequentially through the CAPE system. Your competitors who file first get processed first. If you’re in the same industry importing similar goods, your claim is no more or less valid than theirs — but theirs will be paid sooner. The cost of waiting compounds every week.

Second, competitive dynamics. Companies that recover their IEEPA tariffs early can reinvest that capital into operations, pricing, inventory, or expansion. A competitor who recovers $2 million in Q2 2026 and deploys it for the holiday buying season has a real advantage over one who’s still waiting for their refund in 2027.

How to know if your competitors are filing

You won’t see their specific filings, but you can look for signals:

• Trade association newsletters mentioning IEEPA recovery
• Industry conferences featuring tariff refund sessions
• Customs broker communications about IEEPA preparation
• Peer companies hiring trade law firms or recovery advisors
• Supply chain publications in your sector covering the refund process

If any of these signals are present in your industry, the filing activity is already underway. The question isn’t whether your competitors are preparing — it’s how far ahead they are.

Edge Cases: When Eligibility Isn’t Clear-Cut

Most importers fall clearly inside or outside the eligible universe. But some situations are less straightforward. Here are the edge cases we see most often.

You’re a freight forwarder or 3PL that files as IOR

If your company files entries as the IOR on behalf of your clients, the refund technically belongs to you as the IOR — even though the economic burden of the tariff was borne by your client. This creates a commercial question (do you pass the refund to your client?) layered on top of the legal question (who is entitled to file?). Work with legal counsel to determine the right approach, and review your service agreements for any provisions related to duty refunds.

You imported goods that were partially excluded

During the IEEPA period, the administration granted temporary exclusions for certain products or certain quantities. If some of your entries received exclusions and others didn’t, your refund claim covers only the entries where IEEPA duties were actually assessed and paid. Check your entry summaries carefully for entries where exclusions reduced or eliminated the IEEPA component.

Your company changed IOR numbers during the period

Some companies restructure, merge, or change their IOR number for operational reasons. If your current IOR number differs from the one on entries filed during the IEEPA period, you’ll need to demonstrate continuity (through business records, CBP correspondence, or legal documentation) to file claims on those entries. This is an administrative hurdle, not a substantive one — the refund right follows the legal entity, even if the IOR number changed.

You used a Foreign Trade Zone (FTZ)

Goods admitted to an FTZ and later withdrawn for domestic consumption were subject to IEEPA duties at the time of withdrawal. If your goods were in an FTZ during the IEEPA period and withdrawn during that period, those entries are eligible. If goods were admitted before the IEEPA period but withdrawn during it, the IEEPA duties still apply — and still qualify for refund. FTZ timing can be complex; your customs broker or FTZ operator can help clarify.

What If Only Some Signs Apply?

You don’t need all eight. Even one sign — particularly Sign 1 (you import goods) combined with Sign 2 (during the affected period) — is enough to warrant a closer look at your entry data.

The signs work as a confidence ladder:

The only way to confirm eligibility with certainty is to check your actual entry data. Everything else is a strong indicator, but indicators aren’t proof. Your ES-003 report is the proof.

What to Do Next

If three or more of these signs apply to your company, here’s your action plan:

1. Pull your ES-003 report from the ACE portal (or ask your broker)
2. Search for HTS 9903 codes — their presence confirms IEEPA duties
3. Calculate your total IEEPA exposure using our refund amount calculator
4. Determine your recovery path — the four recovery paths guide explains your options
5. File PSCs immediately for any unliquidated entries
6. Protect liquidated entries by filing protests within the 180-day window
7. Prepare for CAPE filing to secure an early queue position

If that process sounds overwhelming — or if you’d rather have someone else handle the data analysis — that’s exactly what our Impact Assessment does. We pull your data, confirm your eligibility, calculate your exposure, and map every entry to the optimal recovery path. No cost, no obligation, and covered by NDA.

You’ve been paying these tariffs for a year. The Supreme Court said you shouldn’t have been. The process to get your money back is open. The only question is whether you’ll act while the window is wide — or wait until the queue is long and the deadlines have passed.