330,000+ importers are owed IEEPA tariff refunds, but only 6% have completed the required ACH setup. Learn who qualifies, why refunds are being rejected, and how Tariff Refund Authority can help you recover your money now.
The numbers are staggering. According to a sworn declaration filed by CBP's Brandon Lord with the Court of International Trade on March 6, 2026, 330,566 importers have paid duties under IEEPA tariffs that the Supreme Court struck down as unlawful. The total: approximately $166 billion in duties collected across more than 53 million entry transactions.
But here's the part that should alarm every business owner who paid those duties: only 21,423 entities - roughly 6% of those eligible for refunds - have completed the electronic setup process required to actually receive a refund. CBP has already been unable to process 7,700 refunds for 2,897 importers because those businesses haven't taken the necessary steps.
The refunds are not being delayed by government obstruction. They're being rejected because the vast majority of importers haven't registered to receive them. The money is waiting. Most businesses just haven't figured out how to collect it.
And for businesses that can't afford to wait months or years for the bureaucratic process to play out, there's now a way to access that money immediately.
On February 20, 2026, the U.S. Supreme Court ruled that the International Emergency Economic Powers Act does not authorize the president to impose tariffs. The ruling in Learning Resources, Inc. v. Trump was decisive: 6–3, striking down the sweeping tariff regime that had been imposed starting in early 2025.
The legal victory was clear. What followed has been anything but simple.
On March 4, Judge Richard Eaton of the Court of International Trade ordered CBP to begin liquidating and reliquidating affected entries without IEEPA duties - effectively ordering refunds for all importers, not just those who had filed lawsuits. Two days later, on March 6, CBP filed a declaration explaining that immediate compliance was operationally impossible. Processing refunds at this scale manually would require an estimated 4.4 million staff hours. The court suspended the immediate refund requirement while CBP builds out a new automated system called CAPE - the Consolidated Administration and Processing of Entries - within its existing ACE portal.
CBP has stated it is working to have this system operational within approximately 45 days, targeting mid-April 2026. But even once the system is live, the process will require importers to file declarations in ACE listing every entry on which IEEPA duties were paid, have those entries validated and recalculated, and then receive refunds electronically through ACH.
This is not a stimulus check that shows up in your bank account automatically. This is a multi-step federal process involving portal registration, data validation, entry-level reconciliation, and electronic payment enrollment. If you haven't started preparing, you're already behind.
This is the critical distinction that most reporting has missed, and it's why we're publishing this now.
As of February 6, 2026, CBP transitioned to electronic-only refund processing. Paper Treasury checks are no longer issued. Every refund - whether related to IEEPA tariffs or any other duty overpayment - is now processed through the Automated Clearing House system.
To receive an ACH refund, an importer must have an active ACE Portal account with enrolled ACH banking information. Without it, CBP's system literally cannot deliver the refund. It gets rejected.
Out of 330,566 importers who are owed money, only 21,423 have completed this enrollment. That means 94% of eligible businesses are currently unable to receive their refunds even if CBP processes them tomorrow.
CBP has already attempted to issue 7,700 refunds that were kicked back because the receiving importers hadn't set up their accounts. Those refunds weren't denied on the merits. They were rejected on a technicality that the importer could have resolved in advance.
For small businesses that don't deal with customs systems regularly, this is an easy thing to miss. Most importers work through customs brokers and may have never logged into the ACE Portal themselves. But the refund goes to the importer of record, and the importer of record is the one who needs to have ACH set up.
IEEPA tariff refunds apply to importers of record - the entity listed on the customs entry as responsible for paying duties - who paid tariffs imposed under the International Emergency Economic Powers Act between February 4, 2025 and February 24, 2026.
Tariffs that are eligible for refund include:
Tariffs that are NOT eligible for refund under this ruling:
If you imported goods during this period and paid any of the qualifying duties, you are likely owed a refund — plus interest accruing from the date your duties were deposited until the refund is issued. For many businesses, especially those that imported consistently over a 12-month period, the amounts are substantial.
The total refund pool is approximately $166 billion across 330,000+ importers. But knowing you're eligible and actually recovering the money are two very different things.
Not sure if you qualify or how much you're owed? We help businesses identify their IEEPA exposure and calculate potential refund amounts at no cost. → Get Your Free Refund Assessment at TariffRefundAuthority.com
The refund process, once CBP's CAPE system is operational, will require importers to complete a series of steps - each of which carries its own complexity:
1. Register for ACH through the ACE Portal.
This is the baseline requirement, and it's the step that 94% of importers have not completed. Without it, refunds cannot be delivered. The process requires your Taxpayer Identification Number, a U.S. bank account with NACHA-compliant ACH routing information, and an active ACE Portal account. For non-resident importers, additional steps apply.
2. Compile entry-level data separating IEEPA duties from regular duties.
This is where it gets difficult for most businesses. CBP has acknowledged that many importers combined IEEPA duties and regular duties on the same entry summary line, rather than breaking them out by HTS classification as directed. That means identifying the precise IEEPA amounts owed to you may require a detailed manual review of every entry summary filed during the tariff period. For businesses that imported frequently, this could mean hundreds or thousands of individual line items.
3. File declarations in ACE listing every affected entry.
Once CAPE launches, importers will need to submit a declaration that lists all entries on which IEEPA duties were paid. ACE will run validations on each entry, recalculate duties owed, and determine refund amounts with interest. Errors or inconsistencies in the data you submit could delay or complicate your refund.
4. Monitor liquidation status and file protests where necessary.
Entries that have already been liquidated - meaning CBP has finalized the duty assessment - may require a formal protest filed within the 180-day post-liquidation window. If you miss this window, you may lose your right to a refund on those entries entirely. For entries where liquidation is already final and beyond the protest period, recovery may require filing a case with the Court of International Trade.
5. Track ongoing developments as the legal landscape evolves.
The government has signaled it may appeal the CIT's Universal Refund Order. Congress has introduced the Tariff Refund Act of 2026. CBP is issuing new guidance regularly. Missing a single update could mean missing a deadline.
Most small businesses don't have a licensed customs broker on retainer. They don't have a trade attorney reviewing their entries. And they don't have staff monitoring CBP system updates every week. That's exactly why we built Tariff Refund Authority.
We work directly with licensed customs brokers and experienced trade counsel to manage the refund process on behalf of businesses that are owed money but don't have the infrastructure to navigate this on their own. From ACH enrollment to entry review to claim filing, we handle the complexity so you can focus on running your business.
Let us handle the process for you. Our team manages ACH enrollment, entry review, data reconciliation, and claim filing so you don't have to. → Start Your Refund Claim at TariffRefundAuthority.com
Even with CBP's new system targeting a mid-April launch, refund processing at this scale will take time. We're talking about 53 million entry transactions across 330,000+ importers. Trade attorneys who have been through similar federal refund programs - like the Harbor Maintenance Tax refunds of the late 1990s, which took four years to process - estimate that many IEEPA refunds could take two to five years to fully resolve.
For a small business operating on tight margins, waiting two to five years for money you're already owed is not a viable option.
That's why a secondary market has emerged. A growing number of established investment funds are purchasing IEEPA tariff refund claims from importers. The concept is straightforward: the importer receives cash now — a percentage of the total estimated claim value — and the fund assumes the wait time, the processing risk, and the legal complexity. The importer gets immediate liquidity. The fund profits from the eventual full recovery.
This isn't a loan. There are no monthly payments, no interest charges, and no debt on your books. It's a sale of your refund claim - a financial asset - in exchange for cash today.
This model is well-established in other areas of federal claims recovery, including tax credit markets, litigation finance, and structured settlement purchases. What's new is its application to tariff refunds at this scale.
Tariff Refund Authority helps businesses evaluate whether selling their claim makes sense for their situation. We connect qualified importers with vetted funds, ensure you understand the terms and valuation before any transaction, and provide the documentation support needed to complete the sale. There is no cost for the initial evaluation.
Find out what your refund claim is worth today. We provide free, no-obligation valuations for businesses that want to explore selling their IEEPA tariff refund claim for immediate cash. → Get Your Free Claim Valuation at TariffRefundAuthority.com
We believe in being transparent with the businesses we serve. While the legal foundation for IEEPA tariff refunds is strong - the Supreme Court's ruling was unambiguous - the path from ruling to money-in-hand still has open questions:
Will the government appeal the Universal Refund Order?
The CIT's March 4 order applies to all importers, not just those who filed lawsuits. The government has already stated in court that it does not believe every importer is automatically entitled to a refund without filing a claim. An appeal to the Federal Circuit is expected, and the government may argue that the Supreme Court's limits on nationwide injunctions apply here.
What happens to finally-liquidated entries?
The CIT's order addresses unliquidated entries and entries where liquidation is not yet final. It is silent on entries that have been finalized and are beyond the 180-day protest window. Those importers may need to file a case with the CIT to preserve their refund rights.
Will there be hard filing deadlines?
CBP has not yet announced specific deadlines for submitting declarations through CAPE. However, under existing rules, importers generally have two years from the date the cause of action accrued to file suit at the CIT - which would put the earliest deadline at around February 2027 for the fentanyl tariffs. Protest deadlines on individual entries may come sooner.
What about downstream customer clawback claims?
Many importers passed tariff costs on to their customers through price increases. Some of those customers are now asserting claims to a share of the refund. This is an emerging legal issue that could affect how refunds are distributed in certain supply chains.
What about the Tariff Refund Act of 2026?
Congress has introduced legislation (H.R. 7865) that would require the administration to process tariff refunds within 180 days. If passed, this could significantly accelerate the timeline for all importers.
The landscape is evolving weekly. New rulings, new CBP guidance, and new legislative developments are all in motion. We track every update and notify the businesses on our list so you never miss a deadline or an opportunity.
Stay ahead of every tariff refund development. Join our update list and we'll notify you of new rulings, CBP guidance, portal launch dates, and filing deadlines as they happen. → Join the Update List at TariffRefundAuthority.com
The next several weeks will be critical for importers. Here are the key milestones we're tracking:
We'll be publishing updates on each of these as they develop. Bookmark this page and check back, or join our notification list to get updates delivered directly.
Whether you want to file for your full refund, access your money now through a claim sale, or simply stay informed as the process unfolds - Tariff Refund Authority is here to help.
We've built a team of customs brokers, trade compliance specialists, and financial partners specifically to serve importers navigating this unprecedented refund process. There is no cost for your initial assessment.
Three ways we can help:
→ Get Started at TariffRefundAuthority.com
Disclaimer: This article is for informational purposes only and does not constitute legal advice. Tariff refund eligibility, amounts, and processes are subject to change based on ongoing court proceedings, government actions, and CBP system developments. Businesses should consult with licensed customs brokers and qualified legal counsel regarding their specific situations. Tariff Refund Authority is not a law firm and does not provide legal representation. We work with licensed customs brokers and trade attorneys to facilitate the refund process for our clients.
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