Your Money Back: The Importer's Guide to Claiming IEEPA Tariff Refunds
- Mar 14
- 4 min read
Updated: 10-MAR-2026
The dust has settled on one of the most consequential trade rulings in a generation. On February 20, 2026, the U.S. Supreme Court ruled 6-3 that IEEPA does not authorize the president to impose tariffs and that this authority rests with Congress alone. That means every dollar your company paid in IEEPA tariffs since February 4, 2025, is potentially coming back to you.
We're talking real money. CBP has collected approximately $166 billion in IEEPA duties, affecting roughly 53 million import entries across 330,000 importers. If you were sourcing goods from China, India, or virtually anywhere else during 2025, you're likely in that pool.
The good news: you don't need to sue anyone. The bad news: you do need to act now, because the refund queue is already forming and the infrastructure is still being built.
Here's what you need to know.
The Road Map So Far
The Supreme Court's decision had immediate consequences: IEEPA tariff collection ended at 12:00 AM on February 24, 2026. On March 4, Judge Richard K. Eaton of the U.S. Court of International Trade directed CBP to refund IEEPA tariffs to all importers of record, regardless of whether they had filed suit.
That's the sweeping part. The frustrating part is what came next.
On March 6, CBP advised the Court that immediate, entry-by-entry refund implementation was not operationally feasible due to the unprecedented number of affected entries. So the CIT agreed to pause and let CBP build a proper system. CBP is developing new functionality in its ACE platform to streamline and consolidate refund payments, and the framework was announced on March 6, 2026.
The system they're building is essentially a seven-step ACE-based process. Here's how it flows:
CBP is working to have the new ACE functionality ready within 45 days of March 6, placing the target around mid-April 2026. That window may slip. But the process is coming, and you want to be ready the moment it opens.
What You Need to Do Right Now
Don't wait for CBP to flip the switch. Two things you can action today, before any guidance is published.
1. Get Your ACE "Top Account" Set Up
Many importers assume that obtaining an importer of record number automatically creates a profile in the ACE system. In practice, CBP does register the IOR number in ACE, but importers do not automatically receive access to the trading data associated with it. Access is granted only after the importer submits a "Top Account" application linking their IOR number to their ACE profile.
This is your data gateway. Without it, you cannot see your own import history, run entry reports, or submit the declaration that triggers your refund. CBP is currently experiencing significant processing delays on new ACE applications, so apply immediately.
2. Enroll in ACH Refunds
This one is non-negotiable. As of February 6, 2026, CBP no longer issues paper refund checks. All refunds are now processed exclusively through ACE accounts via Automated Clearing House (ACH) electronic transfers.
To enroll, importers must submit an application through ACE and designate a U.S. bank to receive refund payments. Importers already enrolled do not need to reapply. Non-resident importers: you must have a NACHA-compliant U.S. bank account to receive ACH refunds.
3. Pull and Audit Your Entry Data
Once your ACE account is live, run the Entry Summary Details report and export it. You're looking for every entry with IEEPA-specific Chapter 99 classification codes, covering the period February 4, 2025 through February 24, 2026.
CBP has noted that importers frequently combined IEEPA duties and regular duties on the same entry summary line rather than breaking them out by HTS classification. Identifying the precise IEEPA amounts may require detailed manual review. Get your customs broker involved here. This is exactly the kind of data cleanup that pays off when the declaration window opens.
4. Understand Your Liquidation Status
Not all entries are equal. Your options depend on where each entry sits in the liquidation cycle.
What's Still Unknown
Be honest with yourself about the uncertainty here. Timing is the greatest unknown right now. No one knows precisely when the new ACE program will launch, what exactly will be required to file, whether there will be filing deadlines, or how quickly any refund will be received.
There's also the political dimension. The administration has already signaled it will not make this easy. CBP is not issuing guidance on pursuing refunds administratively, and customs brokers are reporting that CBP is automatically rejecting post-summary corrections and protests related to IEEPA tariffs. The government has 60 days from the CIT's March 4 order to appeal. Watch for that.
And a word on the buyout offers circulating right now: some companies are being offered more than 60% of their refund's value to avoid the risk of delayed or denied repayment. Whether that makes sense for your business depends entirely on your cash position and risk appetite. That's a conversation for your CFO and outside counsel, not a decision to rush.
Your Checklist
Get these done before the ACE declaration window opens:
Set up your ACE Top Account (apply now, given processing delays)
Enroll in ACH refund payments through ACE with a valid U.S. bank account
Run the ES-003 Entry Summary report and identify all Chapter 99 entries from Feb 4, 2025 through Feb 24, 2026
Document liquidation dates for every affected entry
File Protests within 180 days for any already-liquidated entries still within the window
Brief your customs broker on what's coming so they can support your ACE filing
Monitor CBP CSMS bulletins for formal guidance on the declaration process
SOLO World Partners is tracking this situation daily. Importers and businesses should begin preparing duty refund calculations and sign up for ACE portal accounts now while the process is being built. When CBP opens the window, the advantage will go to whoever is ready.
Reach out to the SOLO team with questions or to get help with your entry data review.
