Understanding IEEPA Tariff Refunds
The International Emergency Economic Powers Act (IEEPA) tariffs imposed in early 2025 created a wave of unexpected costs for U.S. importers. But many businesses don't realize they may be eligible for substantial refunds on duties already paid.
This comprehensive guide walks you through every step of the refund process — from determining your eligibility to filing your claim with U.S. Customs and Border Protection (CBP).
Who Is Eligible for an IEEPA Refund?
If your business imported goods subject to IEEPA tariffs between February and April 2025, and those tariffs were subsequently reduced or eliminated during the 90-day pause period, you likely qualify for a refund. The key eligibility criteria include:
- Goods entered the U.S. during the active IEEPA tariff period
- Duties were paid at the higher IEEPA rate
- The tariff rate was later reduced for your product category
- You have documentation of the original entry and payment
Step 1: Gather Your Documentation
Before filing, you'll need to compile a complete set of customs entry documents. This includes your CBP Form 7501 (Entry Summary), commercial invoices, bills of lading, and proof of duty payment. Missing documentation is the number-one reason refund claims are delayed or denied.
Step 2: Determine the Refund Amount
Calculate the difference between what you paid under the IEEPA tariff rate and the applicable rate after reduction. For many importers, this difference ranges from 10% to 34% of the declared value of goods.
Step 3: File Your Protest with CBP
Refund claims are filed as protests under 19 U.S.C. § 1514. You must file within 180 days of the liquidation date of the entry. We recommend working with a licensed customs broker to ensure your protest is properly formatted and includes all required supporting evidence.
Common Mistakes to Avoid
The most frequent errors include missing the filing deadline, using incorrect HTS codes, failing to include proof of the rate change, and not specifying the exact refund amount requested. Each of these can result in a denial that is difficult to appeal.
Timeline and What to Expect
After filing, CBP typically takes 30-90 days to review a protest. If approved, refunds are issued as credits against future duties or as direct payments. Complex cases involving multiple entries may take longer.