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5 Mistakes That Can Jeopardize a Tariff Refund

Sep 9, 2026
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You paid IEEPA tariffs. The Supreme Court said they were unlawful. Refunds are going out.

So the money is coming back to you, right?

Not automatically. And not to every importer on the same terms.

The government is already paying billions in IEEPA refunds, but the path you take decides whether you collect all of it, some of it, or none of it. The importers who lose out usually aren't unlucky. They made an avoidable mistake early and found out too late.

Here are the five we see most often, and how each one puts your refund at risk.

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Mistake 1: Waiting for CBP to pay you automatically

This is the big one.

U.S. Customs and Border Protection (CBP) built an automated refund process after the ruling. It's paying out on many entries. That's real, and it's good news.

But CBP has already backed away from paying everyone the same way. For entries that have already finalized, the trade court has ordered full refunds only for importers who filed their own lawsuit. Importers who sat back and waited have no confirmed path to that same money right now.

On top of that, the government is appealing part of the refund order. It filed that appeal on June 2, 2026, and it's targeting exactly the group that didn't sue.

So "wait and see" isn't a neutral choice. For some of your entries, it's the difference between a court-backed right to a refund and a maybe.

Not sure whether waiting is costing you anything? Call us at (602) 649-3887 and we'll walk through where your entries stand.

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Mistake 2: Missing the deadline to preserve your claim

Refund rights don't stay open forever. Two clocks matter here, and neither one waits for you.

First, the way you protect an IEEPA refund is by filing a case at the Court of International Trade (CIT), the federal court that handles customs disputes. You might expect to file a "protest" with CBP, which is the normal way importers dispute duties. That doesn't work here. The court ruled that IEEPA duties aren't the kind of charge you can protest, so a timely lawsuit is the tool that preserves your rights.

Second, the court only has a two-year window to hear these cases. The earliest IEEPA entries, from early 2025, start hitting that wall in early 2027.

That sounds far away. It isn't, once you account for the work of identifying entries, confirming what was paid, and getting a complaint on file correctly.

Miss the window and the claim is gone. There's no late-filing fix for a blown statutory deadline.

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Mistake 3: Assuming every tariff you paid is refundable

Only the IEEPA tariffs were struck down. Nothing else.

The tariffs on steel, aluminum, and autos (Section 232) are still in force. The tariffs on many Chinese goods (Section 301) are still in force. And the government has since added a new round of duties under a different law (Section 122) to replace the lost revenue.

None of those are refundable under this ruling.

So if you treat your entire tariff bill as a refund pool, you'll overstate what you're owed and waste effort chasing duties that aren't coming back. The work is separating the IEEPA dollars from everything else, entry by entry. That separation is where a lot of self-run claims go wrong.

Want a straight answer on which of your duties actually qualify? Find out if your imports qualify for an IEEPA refund.

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Mistake 4: Working from incomplete import data

Your refund is only as good as the entry data behind it.

To claim correctly, someone has to pull your full import history from ACE, the government system that holds your entry records, and find every entry that carried an IEEPA duty. That means the right importer ID numbers, the right entries, and proof that IEEPA tariffs were actually paid on them.

Miss entries and you leave money behind. Include the wrong ones and you hand the government a reason to challenge the claim.

This isn't a quick export you eyeball in a spreadsheet. Entries liquidate, meaning CBP finalizes them, on their own separate schedules, and each one has to be matched and checked. Getting the data right is most of the job.

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Mistake 5: Undervaluing the refund

Your refund isn't just the tariff dollars you paid.

The government owes statutory interest on top of the principal, which is interest for holding your money while the tariffs were in place. The refunds already going out include it. If your number is only "what we paid in IEEPA duties," you're understating the claim.

There's a flip side too. As the government replaces this tariff revenue through other trade laws, you should not assume those new duties come back to you, and you should watch for anything that reduces what you actually collect.

Getting the valuation right, principal plus interest, on every qualifying entry, is what turns an estimate into a real number you can plan around. Getting it wrong means leaving money on the table or being surprised when the actual deposit is smaller than you expected.

Not sure if your valuation is accurate? Call us at (602) 649-3887 and we'll walk through it with you.