When the Supreme Court struck down IEEPA tariffs in February 2026, thousands of electronics importers suddenly had money owed to them by the federal government. But knowing you’re owed a refund and actually recovering it are two very different things. This is the story of how one mid-size electronics importer — we’ll call them Pacific Digital Supply — went from a vague awareness that tariffs might be refundable to a confirmed recovery of $2.3 million. Every step, every complication, every decision point is laid out here so you can map your own situation against theirs.
Pacific Digital Supply imports consumer electronics components — display modules, battery assemblies, PCB boards, and finished accessories — primarily from factories in Shenzhen and Dongguan. Their annual import volume runs about $10 million in declared customs value, spread across roughly 400 entry summaries per year. They’d been paying IEEPA tariffs since February 2025, absorbing the cost through a combination of margin compression and selective price increases to their retail partners.
Discovery: Realizing the Scale of What Was Owed
Pacific Digital’s CFO first heard about the Supreme Court ruling through an industry newsletter the day it dropped. His initial reaction was cautious optimism — he assumed some refund process would emerge but expected it to take years and involve significant legal fees. What he didn’t know was the scale of what his company was owed.
The first step was pulling data. Pacific Digital’s customs broker generated an ES-003 report from the ACE portal, which listed every entry summary filed during the IEEPA period. The report showed 412 entry summaries between February 4, 2025, and February 24, 2026, with IEEPA duties totaling $2.47 million. That number hit harder than anyone expected — the company had been tracking tariff costs internally, but their estimates were roughly 15% lower than the actual figure because they hadn’t accounted for some ancillary charges and mid-year tariff rate increases.
Key finding: The ES-003 report showed that 287 of those entries were still unliquidated, meaning they were eligible for the fastest refund path. The remaining 125 entries had already liquidated, which meant they’d need a different approach.
This split between liquidated and unliquidated entries is common for importers who’ve been filing for a full year. Entries typically liquidate about 314 days after filing, so entries from the first several months of the IEEPA period were already locked in. Understanding this split early was critical because it determined which recovery paths were available.
What the Numbers Looked Like
| Category | Count | IEEPA Duties |
|---|---|---|
| Unliquidated entries | 287 | $1,710,000 |
| Liquidated entries (within 180-day protest window) | 98 | $570,000 |
| Liquidated entries (approaching window close) | 27 | $190,000 |
| Total | 412 | $2,470,000 |
The $2.3 million recovery figure (rather than the full $2.47 million) accounts for a small number of entries where documentation issues required additional work, plus the discount Pacific Digital accepted on a portion of their claim that they chose to monetize through immediate capital rather than wait for the government timeline.
The Impact Assessment: Turning Raw Data Into a Recovery Plan
Pacific Digital’s next step was completing a formal Impact Assessment. This isn’t just a summary of what you’re owed — it’s a strategic document that maps every entry to a specific recovery path, identifies documentation gaps, flags deadline risks, and provides a clear financial picture of expected recovery under different scenarios.
The assessment process took about five business days. Here’s what it involved:
Data collection. The ES-003 report was the foundation, but it needed to be cross-referenced against Pacific Digital’s internal purchase orders, commercial invoices, and HTS classification records. Several entries had been classified under general electronics headings rather than the specific IEEPA tariff codes, which meant the ES-003 data needed manual verification.
Entry-level analysis. Each of the 412 entries was categorized by liquidation status, tariff rate applied, origin country, and product type. This granular view revealed that 34 entries had been assessed at 34% rather than 20% because they fell under the higher tier of China-origin IEEPA rates. Those 34 entries alone accounted for nearly $400,000 in refundable duties.
Deadline mapping. The assessment flagged 27 entries where the 180-day protest window was closing within 60 days. These became the highest-priority items because missing the protest deadline would force them into CIT litigation, which is slower and more expensive.
Recovery path assignment. Based on the analysis, each entry was assigned to one of the four recovery paths:
- Post-Summary Correction for the 287 unliquidated entries — the fastest government path
- Protest filing for the 98 liquidated entries within the standard window
- Expedited protest for the 27 entries approaching deadline
- Immediate capital consideration for a subset of entries where Pacific Digital wanted faster liquidity
The completed assessment gave Pacific Digital’s CFO a one-page summary with the total expected recovery, a timeline for each tranche, and a recommended action plan. It also identified $47,000 in entries where the documentation was incomplete — entries where the original commercial invoices couldn’t be located, requiring reconstruction from broker records.
Path Selection: Why They Used Three Recovery Methods
Most importers don’t use just one recovery path. Pacific Digital ended up using three, which is typical for a company with a full year of import history under IEEPA.
Post-Summary Corrections for Unliquidated Entries
The 287 unliquidated entries were the easy wins. Pacific Digital’s customs broker filed Post-Summary Corrections through ACE, requesting removal of the IEEPA tariff codes. Because these entries hadn’t been liquidated yet, CBP could simply recalculate the duties without the IEEPA surcharge and issue the refund as part of the normal liquidation process.
Timeline: The PSCs were filed in batches over two weeks. CBP processing took approximately 30 days for the first batch. Total time from filing to refund: 6-8 weeks for most entries.
Recovery: $1,710,000 — the full amount of IEEPA duties on those entries.
Protest Filings for Liquidated Entries
The 125 liquidated entries required formal protests under 19 U.S.C. Section 1514. Pacific Digital’s broker filed these through ACE, citing the Supreme Court ruling as the basis for the protest. The 27 entries approaching their deadline were filed first, within a week of the assessment being completed.
The protest process is more involved than a PSC. Each protest needs to reference the specific entry, the tariff provision being challenged, and the legal basis for the challenge. With the Supreme Court ruling providing clear legal authority, the protests were straightforward — but they still needed to be filed correctly and within the window.
Timeline: Protests were filed within three weeks. CBP has 180 days to respond to a protest, but given the volume of IEEPA protests and the clear legal mandate from the CIT’s March 4 order, processing is expected through CAPE once it launches.
Expected recovery: $760,000 — the full amount on all 125 liquidated entries.
Immediate Capital on a Subset
Here’s where Pacific Digital made a strategic choice. They had a seasonal inventory buy coming up in Q2 2026 and needed working capital. Rather than wait 12-18 months for the protest refunds to process through CAPE, they chose to assign $300,000 of their protest-path claims to a claim buyer in exchange for immediate payment at a discount.
The immediate capital path isn’t right for everyone, but for Pacific Digital, the math worked. They received roughly $255,000 within 14 business days — a 15% discount from face value — and deployed that capital into inventory that generated returns exceeding the discount within one quarter.
Net recovery on the assigned claims: $255,000 (received immediately) vs. an estimated $300,000 they would have received 12-18 months later. After accounting for the time value of money, the effective cost of early access was closer to 8-10%.
The Documentation Challenge
Pacific Digital’s recovery wasn’t without complications. The biggest headache was documentation gaps.
Thirty-four entries from early in the IEEPA period had been filed by a different customs broker — Pacific Digital had switched brokers in May 2025. The original broker had the entry data in their system but was slow to release it. This is a common problem, and it delayed the PSC filings on those entries by about three weeks. If you’ve changed customs brokers during the IEEPA period, get ahead of this issue now.
Another issue: seven entries had discrepancies between the declared value on the entry summary and the commercial invoice amount. These were small variances — typically under $500 per entry — caused by currency conversion timing. But they needed to be reconciled before filing because CBP will flag inconsistencies during CAPE processing.
The lesson from Pacific Digital’s experience: start your data audit now, before CAPE launches. The importers who will recover fastest are the ones who’ve already cleaned their data and resolved discrepancies.
Documentation Checklist That Pacific Digital Used
| Document | Source | Status |
|---|---|---|
| ES-003 Report | ACE Portal (via broker) | Complete |
| Entry summaries (CF 7501) | Customs broker records | Complete (both brokers) |
| Commercial invoices | Internal procurement files | 98% complete — 7 reconstructed |
| Packing lists | Supplier records | Complete |
| Bills of lading | Freight forwarder | Complete |
| HTS classification worksheets | Customs broker | Complete |
| Proof of payment (duty receipts) | ACE / bank records | Complete |
Outcome and Timeline
Pacific Digital’s total recovery will reach approximately $2.3 million when all paths are fully processed. Here’s the breakdown by timeline:
Received within 60 days: $1,965,000
- $1,710,000 from Post-Summary Corrections
- $255,000 from immediate capital on assigned claims
Expected within 12-18 months: $460,000
- Remaining protest claims processing through CAPE
Pending resolution: $47,000
- Entries with documentation issues being reconstructed
The speed of the PSC refunds surprised Pacific Digital’s CFO. He’d budgeted for a 6-month wait on government refunds, and the first PSC checks arrived in under two months. The protest-path refunds will take longer, but the bulk of the recovery was in hand within a quarter.
What Pacific Digital Would Do Differently
When I asked Pacific Digital’s CFO what he’d change about the process, he had three answers:
Start earlier. “We waited two weeks after the ruling before doing anything. Those two weeks didn’t cost us money directly, but they pushed back our CAPE queue position and added unnecessary stress on the entries approaching their protest deadlines.”
Consolidate broker data immediately. “The broker switch created a data gap that took three weeks to close. If we’d requested our historical data from the old broker the day the ruling dropped, we’d have been ready to file everything at once.”
Consider immediate capital for a larger share. “The $255,000 we got in 14 days went straight into inventory that generated significant returns. In retrospect, we probably should have assigned a larger portion of our protest claims to immediate capital instead of waiting.”
The Interest Component: Money Most Importers Forget
One financial detail that Pacific Digital’s CFO initially overlooked: statutory interest on IEEPA refunds. Under 19 U.S.C. Section 1505(c), CBP pays interest on duty refunds from the date the duties were deposited to the date of the refund. The rate is set quarterly by the IRS and has been running around 5% annually.
For Pacific Digital, the interest calculation looked like this:
- Average IEEPA duty deposit date: approximately August 2025 (midpoint of the IEEPA period)
- Expected PSC refund date: approximately May 2026
- Time elapsed: approximately 9 months
- Interest on $1.71M in PSC refunds: approximately $64,000
The interest on protest refunds will be even higher because the elapsed time is longer — those refunds won’t arrive until 2027 or later, meaning 2+ years of interest accrual.
Total estimated interest across all paths: approximately $125,000. That’s money Pacific Digital hadn’t included in their initial recovery estimate. It’s not trivial — it covers the cost of two additional inventory cycles.
The interest component is another reason why the immediate capital discount ($17,100 on $300,000 in claims) was less costly than it appeared on the surface. The claim buyer assumes the right to collect the statutory interest on the assigned claims, which partially offsets the discount from Pacific Digital’s perspective.
How Pacific Digital Used the Refund Capital
With $1.96 million in hand within 60 days, Pacific Digital’s CFO had a clear deployment plan:
$800,000 went to inventory. The company had been under-ordering since IEEPA tariffs compressed margins. With margins restored and capital available, they ramped inventory back to pre-IEEPA levels.
$500,000 went to pay down their credit line. Pacific Digital had been running at 70% utilization on their revolving credit facility — uncomfortably high. The paydown brought utilization to 40%, reducing interest expense and improving the company’s banking relationship.
$400,000 went to a new product launch. Pacific Digital had been deferring a move into smart home accessories because the IEEPA tariff made the margin structure unworkable. With tariffs gone and refund capital available, the launch moved forward.
$260,000 went to general working capital reserves. The IEEPA period had taught Pacific Digital’s CFO the value of cash reserves. Having a buffer means never being forced into unfavorable decisions by cash constraints.
This deployment pattern — reinvestment in the business plus debt reduction plus strategic initiative — is typical of what we see among mid-size importers who receive their IEEPA refunds. The refund isn’t just a recovery of past costs. It’s growth capital.
Mapping This to Your Situation
Pacific Digital’s scenario is representative of a mid-size electronics importer, but the principles apply across industries. The key variables are:
- Total IEEPA duties paid — determines your recovery ceiling
- Liquidation status split — determines which paths are available
- Documentation completeness — determines how fast you can file
- Cash flow needs — determines whether immediate capital makes sense for part of your claim
If you import from China under HTS 9903.01 or 9903.02 headings, you’re in a similar position to Pacific Digital. The refund is there. The question is how quickly and efficiently you recover it.
Your first step is the same as theirs: get your Impact Assessment completed. It’s free, it takes about a week, and it gives you a clear picture of exactly what you’re owed and exactly how to get it back.
Ready to see what your recovery looks like? Get your free Impact Assessment →
The importers who recover fastest are the ones who started first. Pacific Digital’s $2.3 million recovery began with a single data pull from their customs broker. Yours can start the same way — request your ES-003 report today, and let us map your recovery path. The CAPE system is expected to launch in mid-April 2026, and the importers with validated data ready on day one will be processed first. Don’t leave your refund sitting in a government queue longer than it needs to be.
