Tariff Refund Amounts: How Much Could Your Business Recover? (2026)

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Tariff Refund Amounts: How Much Could Your Business Recover? (2026)

The Total Refund Pool

The Supreme Court's February 20, 2026 ruling striking down all IEEPA tariffs created what may become the largest single government refund event in U.S. history.

Two major estimates frame the total refund liability:

  1. $133.5 billion: CBP's reported collections through December 14, 2025, representing duties actually collected under IEEPA authority
  2. Up to $175 billion: Penn Wharton Budget Model estimate including collections through February 2026 and projected interest

For perspective, the IEEPA tariffs were projected to raise $1.4 trillion from 2026 through 2035 if allowed to continue. The Tax Foundation has called the ruling one of the most significant fiscal events in recent history.

These figures cover approximately 34 million import entries from 301,000 U.S. importers — spanning every major industry that imports goods into the United States.

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Refund Amounts by Tariff Type

Not all tariff rates were equal. Your refund amount depends on which IEEPA tariffs your business paid:

  1. Liberation Day reciprocal (most countries) — Rate: 10-50%, Effective Dates: April 5, 2025+, Refundable?: Yes
  2. China IEEPA tariffs — Rate: Up to 145%, Effective Dates: February 4, 2025+, Refundable?: Yes
  3. Canada fentanyl tariffs — Rate: 25% (10% energy), Effective Dates: February 4, 2025+, Refundable?: Yes
  4. Mexico fentanyl tariffs — Rate: 25%, Effective Dates: February 4, 2025+, Refundable?: Yes
  5. Steel & aluminum (Section 232) — Rate: 50%, Effective Dates: Pre-2025, Refundable?: No — still in effect
  6. China trade practice (Section 301) — Rate: Varies, Effective Dates: 2018+, Refundable?: No — still in effect

The critical distinction: only tariffs imposed under IEEPA authority are refundable. Section 232 tariffs on steel and aluminum (currently at 50%) and Section 301 tariffs on Chinese goods remain in effect and were not challenged in the Supreme Court case.

Tariff Stacking: Why Amounts Get Complex

Many imports were subject to multiple tariff layers simultaneously. A single shipment from China could have been hit with:

  • IEEPA tariff (up to 145%) — now refundable
  • Section 301 tariff (varies) — still owed
  • Standard MFN duty — still owed

This stacking means your refund won't equal the total duties you paid. It requires careful analysis of each entry to identify which portion was collected under IEEPA. A trade attorney can separate these layers and calculate the exact refundable amount.

Factors That Affect Your Refund Amount

Several variables determine your individual refund:

Import Volume and Frequency

Businesses that imported consistently from affected countries throughout 2025 will have the largest refund claims. A company that imported $10 million in Chinese goods at the 145% IEEPA rate paid $14.5 million in IEEPA tariffs alone — all of which is now potentially refundable.

Product Classification (HTS Codes)

Your Harmonized Tariff Schedule (HTS) codes determine which tariff rates applied. Some products had exemptions or different rate schedules. Entry summaries from CBP's ACE portal will show the exact tariff lines assessed on each import.

Country of Origin

Tariff rates varied by country. China-origin goods faced the highest IEEPA rates (up to 145%), while most other countries faced 10-50% under Liberation Day tariffs. Canada and Mexico had 25% fentanyl/trafficking tariffs.

Liquidation Status

Whether your entries have been liquidated — meaning CBP finalized the duty assessment — affects both your refund pathway and timeline. Unliquidated entries are generally faster to correct. See our how to file guide for detailed pathway information.

Contractual Pass-Through Arrangements

Some businesses contractually passed tariff costs to customers or vendors. If your vendor contracts include tariff pass-through clauses, refund allocation may need to be addressed through those agreements. The legal refund goes to the importer of record regardless.

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Tariff Rebate Timeline: When Will You Get Paid?

Refund processing timelines vary significantly by pathway:

Post-Summary Correction (Fastest)

For unliquidated entries corrected through CBP's ACE portal, refunds are typically issued via ACH within 1-2 business days after approval. This is the fastest route, but only available for entries that haven't been liquidated yet.

CBP Protest

For liquidated entries challenged via CBP Form 19, the timeline is considerably longer. CBP has up to 2 years to review protests, though you can request "accelerated disposition" — if CBP doesn't respond within 30 days of that request, the protest is deemed denied, allowing you to escalate to the Court of International Trade.

Court of International Trade

CIT lawsuits have the longest timeline but offer the most comprehensive protection. Over 2,000 companies filed protective lawsuits before the ruling, including Costco, Toyota, and Revlon. These cases will now proceed through the courts to determine the exact refund mechanism.

Justice Kavanaugh warned in his dissent that the refund process "is likely to be a 'mess'" — underscoring why early filing and legal representation matter.

Early Filers Get Priority

With 301,000 importers and 34 million entries to process, CBP will handle claims on a rolling basis. Filing early doesn't just protect your legal rights — it puts you closer to the front of the refund queue.

Interest on Refunds

Importers may be entitled to interest on unlawfully collected duties. The legal basis for interest exists under customs law, but the exact calculation method is still being determined by the courts.

Key considerations:

  1. Interest typically accrues from the date duties were paid
  2. The rate is set by statute and linked to federal interest rates
  3. Interest compounds the value of larger, older claims
  4. CIT has the authority to order interest as part of reliquidation

This is another reason why an attorney can significantly increase your total recovery — interest calculations on hundreds or thousands of entries require specialized expertise.

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What Won't Be Refunded

Understanding what remains in effect helps you calculate realistic refund amounts:

Section 232 tariffs (National Security)Steel and aluminum tariffs remain at 50% (25% for UK imports). The Trump administration has 12 ongoing Section 232 investigations on additional products including copper, heavy trucks, and auto parts.

Section 301 tariffs (Trade Practices)China tariffs imposed during Trump's first term in 2018 remain in effect. These require U.S. Trade Representative fact-finding, unlike the unilateral IEEPA authority the Court struck down.

Standard MFN duties — Normal customs duties that existed before any Trump-era tariffs continue to apply at their pre-existing rates.

Trump's "Plan B" tariffs — The administration has announced plans for a 10% across-the-board tariff under different statutory authority. These potential future tariffs do not affect your existing refund rights for IEEPA tariffs already paid.

Industry-Specific Refund Context

Manufacturing

Manufacturers importing raw materials and components from China faced some of the highest IEEPA rates — up to 145%. These companies often have hundreds or thousands of individual entries, making the aggregate refund substantial but complex to calculate.

Retail and E-Commerce

Retailers importing finished consumer goods paid Liberation Day rates of 10-50%. Companies like Costco have already filed lawsuits seeking refunds.

Agriculture and Food

Agricultural importers from Canada and Mexico faced 25% fentanyl/trafficking tariffs. Those importing from China faced additional IEEPA layers. Perishable goods importers often have high entry volumes with relatively lower per-entry value.

Automotive

Auto parts importers from all affected countries face complex refund calculations due to tariff stacking between IEEPA, Section 232 (auto parts), and pre-existing duties. Toyota Group and AGS Company Automotive Solutions are among the lead litigants.

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Tariff Refunds Knowledge Base

Read the latest information on Tariff Refunds and find answers to your questions. Currently there are 5 topics about Tariff Refunds .

  • Tools & Resources

    • Estimate how much your business could recover from the $133.5B IEEPA tariff refund pool

      Tariff Calculator

    Frequently Asked Questions

    • The total IEEPA tariff pool is approximately $133.5 billion, collected between February 2025 and the Supreme Court ruling. However, actual refunds depend on claims filed, and not all importers will file. The federal government may also seek to offset some refunds through legislative action.

    • Under 19 U.S.C. § 1505(c), CBP pays interest on refunds at rates published quarterly. Current rates are approximately 3-4% annually. Interest accrues from the date duties were deposited until the refund is issued, which can add meaningful amounts for entries from early 2025.

    • Congress could theoretically pass legislation to ratify the tariffs retroactively, though this faces significant constitutional and political hurdles. The executive branch cannot override a Supreme Court ruling. CBP may create processing delays due to claim volume, but cannot legally deny valid refund claims.

    • Pull your entry summaries from CBP’s ACE portal and identify lines assessed under IEEPA authority. Sum the IEEPA-specific duty amounts across all entries. For complex cases with tariff stacking or mixed authorities, consult a trade attorney for accurate calculations.

    • Your refund eligibility is not affected by whether you passed tariff costs to customers. The importer of record who paid duties to CBP receives the refund regardless of downstream pricing decisions. How you handle customer relationships after receiving a refund is a separate business decision.

    • If you previously deducted tariff payments as a business expense, the refund would generally be taxable income in the year received. Interest payments on refunds are also taxable. Consult your tax advisor for your specific situation, as the treatment depends on your prior tax filings.

    More About Tariff Refunds

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