A ruling from the U.S. Supreme Court has created potential refund opportunities for businesses that paid tariffs under the International Emergency Economic Powers Act. WonderTrust helps businesses identify affected import entries, organize documentation, and prepare for the refund process.
Beginning in 2025 and continuing into 2026, the U.S. government imposed tariffs on certain imported goods under authority claimed through the International Emergency Economic Powers Act (IEEPA). These tariffs affected businesses across a range of industries and created significant additional import costs.
A group of importers challenged the legality of these tariffs in federal court, arguing that the administration exceeded the authority granted under IEEPA when imposing global tariffs. On February 20, 2026, the U.S. Supreme Court ruled in Learning Resources v. Trump that the administration did not have authority to impose global tariffs under IEEPA.
While the decision addressed the legality of the tariffs, it did not establish a clear administrative process for how refunds should be issued. Following that decision, on March 4, 2026, the U.S. Court of International Trade directed U.S. Customs and Border Protection (CBP) to remove certain IEEPA duties from affected import entries and begin implementing a refund framework.
Additional developments are expected as the federal government continues to develop the process for reviewing import entries and issuing potential IEEPA tariff refunds.
Businesses that imported goods into the United States during the period when IEEPA tariffs were in effect may potentially be eligible. Because tariff payments are tied to specific import entries and classifications, eligibility will likely depend on the details of each individual import transaction.
The refund process is still being developed by the federal government. The timing and mechanics of how refunds will be issued will depend on the administrative infrastructure being built by CBP.
Import duties are typically finalized through a process known as liquidation, which occurs after U.S. Customs completes its review of an import entry. Entries that have not yet reached final liquidation status may be adjusted through administrative liquidation or reliquidation procedures.
For entries that have already reached final liquidation status, additional procedures or legal actions may be required to reopen the entry and request a refund.
CBP has indicated that system upgrades within the Automated Commercial Environment (ACE) may be required before large-scale adjustments can be processed. Government filings reference the development of a new module — the Consolidated Administration and Processing of Entries (CAPE) — which may help facilitate the review and processing of affected import entries.
Many businesses do not maintain detailed records of tariffs paid on imported goods. Import tariff information is often managed by third parties, and because tariffs are recorded at the individual shipment level, businesses may have hundreds or thousands of separate import entries across multiple years.
As additional guidance is released, businesses that have already organized their records and analyzed their import data will be better positioned to respond quickly and efficiently.
Businesses that believe they may be eligible should begin organizing import and tariff records in advance of the official refund process. Having documentation ready will make it faster to respond once the process is finalized.
WonderTrust helps educate businesses on current IEEPA tariff refund developments and, where appropriate, assists qualifying businesses in preparing for potential refund processes through a structured approach focused on document collection, import tariff analysis, and readiness for evolving filing requirements.
Analyzing import tariff data and determining potential refund amounts can be complex, particularly for businesses with a large volume of import activity across multiple years.
WonderTrust monitors legislative, judicial, and administrative developments relating to IEEPA tariffs and assists businesses in organizing and analyzing import records in order to better understand potential refund opportunities.
This process may include gathering documentation from customs brokers, reviewing entry summary data, analyzing tariff classifications, and identifying import entries that may have been subject to IEEPA tariffs.
Businesses that imported goods during the relevant period can complete a short assessment to help evaluate whether they may have paid IEEPA tariffs that could ultimately be eligible for refunds.
WonderTrust is committed to monitoring, collating, and disseminating reliable information with respect to IEEPA tariff matters. The IEEPA tariff refund process is currently being developed by the federal government and will likely be impacted by future court rulings, administrative guidance, and/or legislation. Eligibility for and availability of IEEPA tariff refunds will be specific to each business based upon its unique facts and circumstances. WonderTrust is not a governmental agency. We rely on experienced consultants who monitor legislative, judicial, and administrative developments relating to IEEPA tariffs.