Advisory Insight
A recent ruling from the United States Supreme Court has created potential refund opportunities for businesses that paid tariffs under the International Emergency Economic Powers Act (IEEPA).
The U.S. Supreme Court determined that tariffs imposed under the IEEPA were not authorized—opening the door for businesses to obtain refunds of IEEPA tariffs.
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. CBP has since indicated that the scale of the issue is significant and that additional administrative procedures may be required before refunds can be processed at scale.
As a result, businesses that paid IEEPA tariffs should have an opportunity to recover funds depending on how the refund process is ultimately implemented.
Businesses that imported goods into the United States during the period when the IEEPA tariffs were in effect may potentially be eligible for tariff refunds.
In many cases, the importer of record listed on the customs entry is typically the party responsible for the tariff payment at the time of importation. Importers that worked through customs brokers or logistics providers may need to coordinate with those outside parties to gather the necessary documentation and data related to their import entries.
Because tariff payments are tied to specific import entries and classifications, eligibility will likely depend on the details of each individual import transaction.
Following recent court rulings:
The exact process for issuing refunds has not been finalized. However, based on current court orders and government filings, refunds may depend on the status of individual import entries within the customs system.
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.
U.S. Customs and Border Protection has also 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 known as Consolidated Administration and Processing of Entries (CAPE), which may help facilitate the review and processing of affected import entries.
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.
As additional guidance becomes available, the process for submitting IEEPA refund requests and supporting documentation should become clearer.
Potential amount of tariffs for review
Importers potentially affected
Import entries that could be impacted
Because tariffs are recorded at the individual shipment level, businesses may have hundreds or thousands of separate import entries across multiple years.
Import data is often maintained within the Automated Commercial Environment (ACE), the federal system used to track import entries and tariff payments.
This can make it difficult for companies to determine the total tariffs paid without reviewing detailed import records.
Having these records readily available will make it easier to evaluate potential refund opportunities once the official process is finalized.
WonderTrust helps educate businesses on current IEEPA tariff refund developments and potential opportunities 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.
Step 01
Businesses complete a short assessment outlining their import activity and customs broker relationships. WonderTrust performs an initial review to identify potential areas of exposure and relevance to IEEPA tariff developments.
Step 02
A WonderTrust advisor reviews the assessment information and discusses potential IEEPA tariff considerations, including how recent developments may apply based on the company’s import profile.
Step 03
Step 04
Businesses are supported in organizing documentation and preparing for potential refund processes as additional administrative guidance becomes available.
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 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 the IEEPA tariffs.
Based on this analysis and with our assistance, businesses can begin developing preliminary estimates of potential refunds and preparing documentation that may ultimately be required as part of the refund process.
As additional guidance is released, businesses that organized their records and analyzed their import data will be better positioned to respond quickly and efficiently.
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.
CONTEXT
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.