Every importer asking about IEEPA tariff refunds eventually gets to the same question: how much am I getting back? The answer is straightforward in principle — you’re owed every dollar of IEEPA duties you paid, plus statutory interest — but the calculation has nuances that can mean the difference between a rough estimate and a precise number. And precision matters, because your refund amount drives your recovery path decision, your cost-benefit analysis on professional support, and whether immediate capital makes financial sense for your situation.
This guide walks you through the exact calculation, from identifying your IEEPA duties in ACE data through applying the statutory interest formula, with worked examples at $500K, $2M, $10M, and $50M exposure levels.
The Refund Formula
Your IEEPA tariff refund is calculated as:
Total Refund = IEEPA Duties Paid + Statutory Interest
That’s it. No penalties, no reductions, no administrative fees deducted by CBP. The full amount of IEEPA duties assessed under HTS headings 9903.01 and 9903.02 between February 4, 2025, and February 24, 2026, is refundable. Statutory interest is added on top, calculated from the date you paid the duties to the date CBP issues the refund.
What’s included in “IEEPA Duties Paid”
The IEEPA duty amount on each entry line is the dollar figure assessed specifically under the 9903.01 (China) or 9903.02 (other countries) HTS codes. This is not your total duty bill — it’s only the IEEPA surcharge portion.
For example, if you imported electronics from China and your entry summary shows:
- MFN duty (standard rate): $8,000
- Section 301 duty (9903.88.xx): $25,000
- IEEPA duty (9903.01.xx): $40,000
- Total duties paid: $73,000
Your IEEPA refund on this entry is $40,000 plus interest — not $73,000. The MFN and Section 301 duties are unaffected by the Supreme Court ruling and remain as assessed.
This distinction is critical and is one of the most common calculation errors importers make. If you estimate your refund based on total duties rather than IEEPA-specific duties, you’ll overstate your exposure — potentially by 50% or more — which leads to poor decisions downstream.
How to find the IEEPA amount on your entry summaries
Pull your ES-003 Entry Summary report from the ACE portal for the full IEEPA period. Each entry line shows the HTS code and the corresponding duty amount. Filter for lines containing 9903.01 and 9903.02 codes. The duty amount on those lines — and only those lines — is your refundable IEEPA exposure.
If you’re working with your customs broker, ask them to provide a summary showing total IEEPA duties by entry number, with the HTS subheading and duty amount broken out separately. This is the raw data you need for both the refund calculation and the filing process.
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Statutory Interest: The Number Most Importers Underestimate
Statutory interest on customs refunds is governed by 19 U.S.C. Section 1505(c). CBP is required to pay interest on overpaid duties from the date of the overpayment to the date of the refund. This isn’t optional or discretionary — it’s a legal obligation.
How the interest rate is determined
The statutory interest rate is set quarterly by the IRS and is based on the federal short-term rate plus 2 percentage points. For overpayments (refunds), the rate is typically:
| Period | Approximate Statutory Rate |
|---|---|
| Q1 2025 | 7% |
| Q2 2025 | 7% |
| Q3 2025 | 7% |
| Q4 2025 | 7% |
| Q1 2026 | 6% |
| Q2 2026 (current) | 6% |
These rates compound daily. The actual rate varies quarterly based on IRS adjustments, but for estimation purposes, a blended rate of 6.5% to 7% annually is reasonable for duties paid during the IEEPA period.
The interest calculation
Interest accrues from the date of each duty payment to the date CBP processes the refund. Since IEEPA entries span 13 months (February 2025 through February 2026) and refunds won’t all process simultaneously, the interest period varies by entry.
For a simplified calculation:
Interest = IEEPA Duties Paid x Annual Rate x (Days from Payment to Refund / 365)
For entries paid in early 2025 that receive refunds in mid-2026, that’s roughly 16-18 months of interest — adding approximately 8% to 10% to the base refund amount. For entries paid later in the IEEPA period, the interest component is smaller but still meaningful.
Why interest often exceeds expectations
Most importers focus on the base duty amount and treat interest as a rounding error. It’s not. On a $2 million IEEPA exposure with an average payment date of mid-2025 and a refund date of late 2026, the interest component alone is approximately $160,000 to $210,000. That’s real money — and it’s money you’re entitled to on top of your duty refund.
The longer CBP takes to process refunds, the more interest accrues. Ironically, processing delays benefit you on the interest side — though the time value of your capital typically outweighs the interest gain, especially if your company’s weighted average cost of capital exceeds the statutory rate.
Worked Examples: What Your Refund Actually Looks Like
These worked examples show why importers who estimate only the duty principal understate the actual refund. The gold segment is the statutory interest that accrues on top of the duties paid.
Let’s put real numbers to this. The following examples assume a blended annual interest rate of 6.5% and an average interest accrual period of 14 months (the midpoint of the IEEPA period to an estimated mid-2026 refund date).
Example 1: $500,000 IEEPA Exposure
| Component | Amount |
|---|---|
| IEEPA duties paid | $500,000 |
| Statutory interest (6.5% x 14/12) | $37,917 |
| Estimated total refund | $537,917 |
Profile: A mid-size importer bringing in consumer goods from China or mixed-country sources. Annual import value of $2M-$5M from IEEPA-affected countries. Likely has 50-200 entry lines.
Recovery path consideration: At this exposure level, the CAPE filing system plus customs broker support is typically sufficient. The interest component ($37,917) more than covers the cost of professional advisory support if needed. Filing through the standard process is straightforward, but timing still matters — missing the protest window on liquidated entries could complicate recovery on a meaningful portion of the total.
Example 2: $2,000,000 IEEPA Exposure
| Component | Amount |
|---|---|
| IEEPA duties paid | $2,000,000 |
| Statutory interest (6.5% x 14/12) | $151,667 |
| Estimated total refund | $2,151,667 |
Profile: A larger importer or one with heavy China-origin volume during peak rate periods. Annual import value of $8M-$20M from IEEPA countries. Likely has 200-1,000 entry lines across multiple HTS categories.
Recovery path consideration: At $2M, you’re looking at a refund that materially impacts your P&L. The $151,667 in interest alone exceeds many companies’ annual customs broker budgets. A structured Impact Assessment pays for itself many times over by identifying deadline risks, optimizing path selection across entries, and ensuring no entries fall through the cracks. The CFO guide to IEEPA recovery provides a framework for evaluating this as a capital allocation decision.
Example 3: $10,000,000 IEEPA Exposure
| Component | Amount |
|---|---|
| IEEPA duties paid | $10,000,000 |
| Statutory interest (6.5% x 14/12) | $758,333 |
| Estimated total refund | $10,758,333 |
Profile: A major importer — Fortune 500, large manufacturer, or high-volume distributor. Annual import value of $40M-$100M from IEEPA countries. Thousands of entry lines, potentially multiple customs brokers, multiple IOR numbers.
Recovery path consideration: At this level, the hybrid approach is almost always optimal. Some entries go through PSC (fastest), some through protest (preserving rights), and a portion may justify immediate capital through claim assignment to redeploy $3M-$5M now rather than waiting 18-36 months. The interest component ($758,333) is significant — but if your company’s WACC is 10%, the opportunity cost of waiting 24 months for the full refund is approximately $2 million. That math often tips the scale toward assigning a portion of the claim.
Example 4: $50,000,000 IEEPA Exposure
| Component | Amount |
|---|---|
| IEEPA duties paid | $50,000,000 |
| Statutory interest (6.5% x 14/12) | $3,791,667 |
| Estimated total refund | $53,791,667 |
Profile: A top-tier importer — think major retailer, multinational manufacturer, or high-volume commodity importer. This level of exposure represents a board-level financial event.
Recovery path consideration: At $50M, this is a treasury management project. The interest alone ($3.79M) is a line item. The cost of waiting at a 10% WACC is roughly $5 million per year. These importers typically engage specialized trade advisory firms, retain CIT counsel for finally liquidated entries, and assign a significant portion of the claim for immediate capital. The complete guide to IEEPA tariff refunds provides the full strategic framework for this level of exposure.
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Why Your Actual Refund May Be Higher Than Your Estimate
Several factors systematically cause importers to underestimate their refund:
Rate escalation during the IEEPA period
IEEPA rates on China-origin goods escalated dramatically during the 13-month period. If you estimated your exposure using the initial 10% rate but many of your entries were filed during the 54% or 145% rate periods, your actual IEEPA duty amounts are much higher than a flat-rate estimate would suggest.
Overlooked entry lines
Large importers often have entry lines they don’t immediately associate with IEEPA tariffs. Components, raw materials, and intermediate goods that were assessed IEEPA duties may not show up in a casual review of your import data. The only reliable way to capture every IEEPA entry line is a systematic filter of the ES-003 data for 9903.01 and 9903.02 codes.
Multiple customs brokers
If you used different customs brokers for different shipments or different ports of entry, your IEEPA entries may be split across multiple data sets. A single broker’s report won’t capture your total exposure. You need consolidated data from every broker who filed entries on your behalf during the IEEPA period.
Interest accrual beyond initial estimate
If your estimate assumed a mid-2026 refund date but processing takes until late 2026 or 2027, the interest component grows. An additional 6 months of interest at 6.5% on a $2M exposure adds roughly $65,000 to your refund. CBP delays, while frustrating, do increase the total amount owed to you.
Foreign Trade Zone withdrawals
Goods withdrawn from FTZs for domestic consumption during the IEEPA period were assessed IEEPA duties at the time of withdrawal. If your company uses FTZs, these entries may not appear in the same reports as your standard imports. Verify with your FTZ operator that all IEEPA-assessed withdrawals are included in your data set.
How to Get From Estimate to Exact Number
The examples above use simplified assumptions — blended interest rates, average accrual periods, and rounded duty amounts. Your actual refund will differ because:
- Each entry has its own duty payment date, which determines when interest begins accruing
- Interest rates change quarterly, so entries paid in different quarters accrue at different rates
- Refund processing dates vary by entry depending on your recovery path and CBP’s processing schedule
- Some entries may have partial IEEPA exposure where only certain line items carry IEEPA codes
An entry-level calculation — one that applies the correct interest rate to each entry’s specific payment date and projects a refund date based on the entry’s recovery path — is the only way to get a precise number. This is exactly what an Impact Assessment delivers.
The calculation process
| Step | What Happens | Output |
|---|---|---|
| 1. Data extraction | Pull ES-003 from ACE for full IEEPA period | Raw entry data |
| 2. IEEPA filtering | Isolate 9903.01 and 9903.02 lines | IEEPA-only entries |
| 3. Duty summation | Sum IEEPA duty amounts by entry | Base refund amount |
| 4. Status mapping | Determine liquidation status of each entry | Recovery path assignment |
| 5. Interest calculation | Apply quarterly statutory rates to each entry’s payment date | Entry-level interest amounts |
| 6. Total projection | Sum base duties + interest, adjusted for path-specific timing | Estimated total refund |
For importers with fewer than 50 entry lines, this can be done in a spreadsheet. For importers with hundreds or thousands of lines, it requires systematic data processing — which is why most importers with significant exposure engage professional support.
The Refund vs. Immediate Capital Trade-Off
Your calculated refund is the amount the government owes you. But the government pays on its own timeline — which, based on current CAPE projections and CBP staffing, means 18-36 months from filing for most importers.
If you need capital sooner, claim assignment provides an immediate, non-recourse payment — typically at a discount to the full refund amount. The question every CFO needs to answer is whether the discount is worth the certainty and speed.
The present value framework
Compare your options:
| Option | Amount | Timeline | Present Value (at 10% WACC) |
|---|---|---|---|
| Government refund (CAPE) | $2,151,667 | 24 months | $1,780,000 |
| Government refund (protest) | $2,151,667 | 30 months | $1,710,000 |
| Immediate capital (claim assignment) | $1,700,000 - $1,850,000 | 14-21 days | $1,700,000 - $1,850,000 |
In this example, the “discount” on immediate capital may actually deliver more present value than waiting for the full government refund — depending on your WACC and the actual processing timeline. The CFO guide to IEEPA recovery walks through this analysis in detail.
Common Calculation Mistakes
Five errors that consistently lead to inaccurate refund estimates:
1. Including non-IEEPA duties. Only 9903.01 and 9903.02 duties are refundable. Section 301, Section 232, and MFN duties are not.
2. Using a single flat rate. IEEPA rates varied dramatically by country and by date. A flat 20% estimate on China goods will be wrong for entries filed during 54% or 145% rate periods.
3. Ignoring interest. Statutory interest adds 8-12% to the base refund for most importers. Leaving it out of your estimate means undervaluing your claim.
4. Missing entries from secondary brokers. If you used multiple customs brokers, each one’s data must be consolidated.
5. Double-counting drawback. If you filed drawback claims on entries that also have IEEPA duties, the overlap needs to be netted out. You can’t recover the same duty amount twice.
For a deeper dive into filing errors that cause delays, see our guide on 5 mistakes that delay your IEEPA tariff refund.
The Bottom Line
Your IEEPA tariff refund is the sum of all IEEPA duties paid under HTS 9903.01 and 9903.02 between February 4, 2025, and February 24, 2026, plus statutory interest under 19 U.S.C. Section 1505(c). The interest alone adds 8-12% for most importers. Your actual number depends on entry-level data that only a systematic ACE analysis can provide.
Don’t guess. Don’t use flat-rate estimates. Get the exact number — and then make informed decisions about your recovery path and timeline.
