You qualify for an IEEPA tariff refund if your business was the importer of record on customs entries that included IEEPA tariff charges between April 2025 and February 2026. Over 301,000 importers may be eligible. Downstream buyers who paid inflated prices may also have recovery options, though the path is more complex.
Quick Eligibility Checklist
You imported goods into the U.S. between April 2025 and February 2026
The IEEPA tariffs were in effect during this period
You were listed as the importer of record
The company named on the customs entry summary (CBP Form 7501)
Your entries included IEEPA tariff duty codes
Check your entry summaries for IEEPA-specific HTS codes
Who Is the Importer of Record?
The importer of record is the party legally responsible for ensuring imported goods comply with U.S. laws and for paying all applicable duties and fees. This is the entity named on CBP Form 7501 (Entry Summary).
The importer of record has the clearest legal right to tariff refunds because they are the party who actually paid the duties to CBP. This is true even if:
- A customs broker filed the entry on your behalf
- You later passed the cost to customers
- A foreign supplier shipped the goods
What If I'm Not the Importer of Record?
Downstream Buyers
If you purchased goods from an importer and paid prices that included passed-through tariff costs, you may have recovery options, but the legal pathway is more complex. Possible avenues include:
- Contractual claims against your supplier if your purchase agreement addressed tariff costs
- Assignment of rights if the importer agrees to assign their refund claim to you
- Direct negotiation with the importer for a share of any refund they receive
The clearest path for downstream buyers is to work with the actual importer of record to pursue the refund jointly.
Foreign Suppliers
If you are a foreign company that shipped goods to the U.S., you generally do not have standing to claim IEEPA refunds unless you were also the importer of record. The U.S. importer who paid the duties is the party entitled to the refund.
Industries Most Affected
IEEPA tariffs impacted virtually every industry that imports goods, but some sectors faced particularly high exposure:
Electronics & Technology
Semiconductors, consumer devices, components
Manufacturing
Industrial equipment, machinery, parts
Automotive
Vehicles, auto parts, accessories
Retail & Consumer Goods
Apparel, furniture, household items
Agriculture & Food
Processed foods, ingredients, equipment
Pharmaceuticals
APIs, medical devices, packaging
Common Disqualifying Factors
Entries already final with no protest filed
If liquidation occurred more than 180 days ago without a protest, options may be limited
Non-IEEPA tariffs only
Section 301 (China) and Section 232 (steel/aluminum) tariffs are separate and still in effect
No documentation of payment
You need records showing IEEPA duties were assessed and paid
How to Verify Your Eligibility
- Pull your customs entry summaries for the April 2025 to February 2026 period
- Identify IEEPA duty codes on your entries (your customs broker can help)
- Calculate total IEEPA duties paid across all affected entries
- Check liquidation status to understand which recovery pathway applies
Next Steps
If you believe you qualify, the most important step is to protect your claim before any deadlines pass. A free consultation can confirm your eligibility and identify the right recovery pathway for your specific situation.
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