Updated — February 23, 2026

IEEPA Tariff Refund Center

On February 20, 2026, the Supreme Court struck down Trump's IEEPA emergency tariffs. Importers who paid those duties may be owed billions of dollars in refunds. This page explains who is eligible, what deadlines apply, what documentation to gather, and how the refund process is expected to work.

CBP deactivating all IEEPA codes at 12:01 a.m. EST, Feb 24, 2026

Background: Full Supreme Court ruling explainer →

Current Status — Feb 23, 2026

✓The CIT's stay has been lifted; refund litigation is moving ahead.
✓Law firms and trade advisers broadly agree: IEEPA duties are refundable “in principle.”
!CBP has not yet issued official step-by-step refund procedures. Monitor the Federal Register and CBP CSMS for guidance.
!Refunds are expected to be issued electronically via ACH, leveraging CBP's Feb 6 move to 100% e-refunds.

1. Who Is Eligible?

Any importer who paid duties under one or more of the following IEEPA-based tariff programs may be eligible for a refund. These are tariffs imposed under President Trump's “emergency” declarations, which the Supreme Court has now held lacked legal authority.

IEEPA

"Liberation Day" Blanket Tariff

The ~10% across-the-board tariff applied to most imports from 100+ countries, effective April 5, 2025.

IEEPA

Reciprocal / Penalty Tariffs

Higher country-specific rates imposed on nations with large trade surpluses or "unfair" trade practices.

IEEPA

25% Fentanyl-Related Tariffs

Duties imposed on selected goods from Canada, Mexico, and China under the fentanyl emergency proclamation.

Not eligible for IEEPA refunds: Duties imposed under Section 232 (national security), Section 301 (China unfair trade), Section 201 (safeguards), MFN base rates, or anti-dumping / countervailing duty orders. Those remain in force and are unaffected by the Supreme Court ruling.

2. Key Deadlines & Forums

Two parallel tracks exist for asserting refund claims. The deadlines differ and the right path depends on your specific entries and legal strategy. Consult trade counsel early.

Standard 180-Day Protest (CBP)

Administrative track

—File a protest with CBP within 180 days of liquidation of the entry.
—Standard avenue for challenging CBP classification and duty assessments.
—Does not automatically bar other refund avenues; protest denials can be appealed to the CIT.

CIT 2-Year Filing Window

Judicial track — per AGS Co. Automotive Solutions v. CBP

—The CIT has held it has authority to order refunds even for liquidated entries, with a separate two-year window for IEEPA-related claims.
—Standard 180-day protest rules do not automatically block CIT filings in this context.
—Litigation path if CBP fails to act on administrative claims.

Important: No single, official CBP “IEEPA refund form” has been published yet (as of Feb 23, 2026). Monitor federalregister.gov and CBP's CSMS messaging service for official procedures when published.

3. Documentation Checklist

Start gathering documentation now — before official CBP procedures are published. Preparedness will be critical when deadlines are announced.

Entry summaries (CBP Form 7501)

Pull all entry summaries where IEEPA tariff codes were applied. Filter by entry date (roughly April 5, 2025 through Feb 23, 2026).

Proof of IEEPA duties paid

Confirm which tariff line items on each entry correspond to IEEPA proclamations (e.g., liberation day rates, reciprocal-rate overlays, fentanyl tariff codes).

ACE (Automated Commercial Environment) access

Ensure your importer-of-record account is active in ACE and that your broker has current authorization. Refunds are expected to process electronically.

ACH enrollment with CBP

CBP moved to 100% electronic refunds (ACH) on Feb 6, 2026. Verify your bank account is enrolled for ACH refund disbursements in ACE.

Importer of record documentation

Confirm your Continuous Import Bond is current and the importer-of-record name matches your ACE account to avoid disbursement delays.

Counsel engagement

Engage trade counsel to review your highest-value IEEPA entries, assess protest deadlines, and advise on CIT filings if CBP delays action.

4. Expected Refund Mechanism

No official refund process has been announced as of Feb 23, 2026. However, the legal and operational picture is becoming clearer based on court decisions, law-firm analysis, and CBP's existing systems.

CBP deactivates IEEPA tariff codes (12:01 a.m. EST, Feb 24)

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CBP / Treasury expected to publish official refund procedures

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Importers submit claims via CBP protest process OR CIT filing (two-year window)

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Refunds disbursed electronically via ACH to enrolled bank accounts in ACE

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Disputed or delayed claims litigated at the CIT (Court of International Trade)

Automatic vs. claim-based refunds

Business groups are pushing for automatic, mass refunds without requiring each importer to file individually. Treasury and CBP have not committed to this approach, but political and legal pressure may shape the outcome. An importer relying on automatic processing takes more risk; filing a protective claim is safer.

Scale of potential refunds

Estimates of total IEEPA duties collected range from $100 billion to $175+ billion, depending on the period and scope. The Wharton Budget Model estimates refund exposure in the $130–175 billion range. Over-collection may have continued even after the SCOTUS ruling, as CBP implementation lagged, potentially enlarging the refund pool further.

‼️ BREAKING ‼️

IEEPA Tariff Refund Center

1. Who Is Eligible?

"Liberation Day" Blanket Tariff

Reciprocal / Penalty Tariffs

25% Fentanyl-Related Tariffs

2. Key Deadlines & Forums

Standard 180-Day Protest (CBP)

CIT 2-Year Filing Window

3. Documentation Checklist

4. Expected Refund Mechanism

Automatic vs. claim-based refunds

Scale of potential refunds