IEEPA Tariff Refunds: Start Here

Informational only — not legal advice.

What else changed on Feb. 24, 2026

Also beginning February 24, 2026 (12:01 a.m. ET), CBP started collecting a separate temporary 10% import surcharge under Section 122 (scheduled through July 24, 2026 unless changed). (CBP CSMS #67844987)

CBP states de minimis duty-free treatment remains suspended (not reinstated by the Supreme Court decision). (CBP CSMS #67845486)

If a carrier/brokerage advanced duties and billed them back (common with express shipments), refunds may flow through the party listed as the Importer of Record (IOR). FedEx’s customer alert notes it’s unclear how refunds will be issued, and states FedEx is taking steps to protect refund rights; FedEx also published a statement explaining its intent is to issue refunds to the shippers/consumers who originally bore those charges. Reuters later reported a proposed class action filed by FedEx customers seeking tariff refunds — a live example of why “refund flow” can become disputed when a carrier advanced duties and billed them back. (FedEx alert — Feb. 24, 2026, FedEx — U.S. tariffs impact, Reuters — Feb. 27, 2026)

1) What changed (and what didn’t)

What changed

• Supreme Court decision: IEEPA does not authorize tariff imposition. (Opinion PDF)
• CBP collection stopped for new entries: IEEPA duties are no longer collected for goods entered for consumption (or withdrawn from warehouse for consumption) on or after Feb 24, 2026, and the relevant HTS numbers are inactive in ACE. (CBP CSMS #67834313)
• Executive action ending certain tariff actions: White House EO ending IEEPA duty collection (helps explain the operational transition). (Executive Order — Ending Certain Tariff Actions)
• Section 122 replacement duty began: a separate 10% “temporary import surcharge” applies under Section 122 for a limited period (with exemptions). (CBP CSMS #67844987, White House — Proclamation (Section 122 surcharge))
• De minimis remains suspended: CBP states de minimis treatment remains suspended and current processes remain in place. (CBP CSMS #67845486, White House — EO (continuing de minimis suspension))

What didn’t (or may not have changed for you)

• There is no automatic refund for every importer. Most importers will need to use existing CBP procedures, and the right procedure depends on each entry’s status. (CBP — Protests)
• Many entries include multiple duty types. Your job is to isolate the IEEPA portion using entry data (usually visible on the 7501 / ACE entry summary). (CBP Form 7501 PDF)
• CBP’s CSMS guidance is explicit that the EO affects IEEPA duties only and “does not affect any other duties,” including section 232 and section 301 duties. (CBP CSMS #67834313)

1A) New as of March 12, 2026: CBP's proposed importer-basis refund workflow now has a name and build status

In a declaration filed at the CIT on March 6, 2026, CBP said it was developing new ACE functionality to "streamline and consolidate refunds and interest payments on an importer basis" instead of issuing entry-by-entry refunds across all affected entries. CBP said it was making all possible efforts to have that new functionality ready in 45 days. (CBP declaration, Mar. 6, 2026)

By March 12, 2026, CBP identified that workflow as CAPE ("Consolidated Administration and Processing of Entries") and told the court it was building four integrated components:

• Claim Portal — 70% complete
• Mass Processing — 40% complete
• Review and Liquidation/Reliquidation — 80% complete
• Refund — 60% complete

The same March 12 declaration says the CAPE Claim Portal is intended to be web-based and available in both importer and broker ACE Portal accounts, while the refund component would consolidate payments by liquidation/reliquidation date and the Importer of Record or its Form 4811 designee. (CBP declaration, Mar. 12, 2026)

Later that day, the CIT continued the suspension of immediate compliance and ordered another short progress report by 2:00 p.m. EDT on March 19, 2026. (CIT order, Mar. 12, 2026)

Practical takeaway: the likely refund workflow may become more centralized, but importers should still preserve current rights entry-by-entry until CBP publishes operative guidance.

2) Before you do anything: confirm your role (IOR vs consignee)

Refund rights start with what's on the entry papers:

• Importer of Record (IOR): the party shown on the entry summary as responsible for the entry.
• Ultimate consignee / buyer: often the party that received the goods and paid an invoice, but may not be the IOR and may not control entry documents.

The protest statute allows protests by several categories of parties, including “importers or consignees shown on the entry papers” and “any person paying any charge or exaction,” among others. (19 U.S.C. §1514)

Actionable takeaway: don’t guess. Confirm the IOR using a 7501 (or ACE export) for each entry. If you’re not the IOR, your fastest path is often authorization/cooperation from the IOR and/or the broker who filed the entry.

3) Step-by-step: what to do now

From a practical standpoint, the biggest bottleneck for most importers is step 1 — getting the entry documents. The legal and procedural framework is well-established; the operational challenge is document retrieval from brokers and carriers who handle the records.

Step 1 — Build your entry list (even if it’s messy)

For each potentially affected import, try to capture:

• Entry number (and port)
• Entry date
• Liquidation status/date (if available)
• Broker/filer (carrier brokerage vs independent broker)
• Any reference IDs (tracking/AWB/BOL, commercial invoice #)

If you have the 7501, you can usually extract most of this directly from the form. (CBP Form 7501 PDF)

Step 2 — Gather the documents that actually matter

Start with one of these:

• CBP Form 7501 (Entry Summary) PDFs for each entry, or
• ACE exports / entry summary data that include duties/fees broken out by line.

CBP relies upon Form 7501 (“Entry Summary”) to determine key entry facts (classification, duty calculations, etc.). (CBP — CBP Form 7501)

Step 3 — Determine liquidation status (this changes your options)

CBP’s own guidance is blunt:

• the options depend on entry summary liquidation status, and
• once liquidation occurs, the relief option is to file a protest.

See: CBP — Protests.

Action: for each entry, classify it as liquidated or not yet liquidated (and record liquidation date if liquidated).

If the entry is not yet liquidated: ask about a PSC (pre‑liquidation correction path)

CBP describes a Post Summary Correction (PSC) as the “sole method” to electronically correct entry summaries prior to liquidation in ACE, with eligibility and timing rules. (CBP — Post Summary Corrections)

Practical tip: PSCs are submitted by an authorized ACE entry summary filer. In many cases, that’s your customs broker — so your fastest move is to ask the filer: “Is this entry still PSC‑eligible, and what data do you need from us to submit it?”

If the entry is liquidated: protest is the post‑liquidation remedy (with a real clock)

Once liquidation has occurred, CBP says the path to relief is a protest. Protests can be filed electronically or on paper; CBP also explains how protests are filed in ACE (including setting up a protest filer account). See CBP — Protests and CBP — Protest (ACE guidance).

Step 4 — Put the deadline on a calendar (per entry)

The statute provides a 180‑day protest window after liquidation (with a separate timing rule where liquidation is “inapplicable”). (19 U.S.C. §1514)

If you have multiple entries, don’t think “one deadline.” Think: a deadline per entry based on liquidation date. (See also: /learn/deadlines-liquidation-180-day-clock.)

Step 5 — Make sure refunds can actually get paid (ACH / electronic refunds)

CBP states that beginning February 6, 2026 it will issue refunds electronically via ACH (subject to limited exceptions), and recommends the trade community review FAQs and take necessary action. (CBP — ACH Refunds FAQs)

Even if you’re not ready to file today, it’s worth validating:

• Your organization’s ACE/CBP account access is in order
• The receiving bank info and permissions are correct

Step 6 — Don’t confuse new duties with refundable IEEPA duties

Starting February 24, 2026, CBP implemented a separate Section 122 temporary import surcharge (an additional 10% ad valorem duty for 150 days, with exemptions). (CBP CSMS #67844987)

Action: separate “IEEPA duties paid historically” (refund target) from “post‑Feb 24 duties under other authority” when doing calculations.

4) Have documents vs don’t have documents

If you already have documents (7501s / ACE exports)

You’re in the fast path:

1. Upload the docs (or consolidate ACE exports)
2. Ensure each record includes entry number + liquidation info (or enough to obtain it)
3. Flag entries where you are not the IOR (these often require authorization/cooperation)

If you don’t have documents

Your immediate goal is “get entry numbers + 7501s” (not “argue eligibility”).

Start with:

• The broker/carrier that cleared your imports (express carriers often have in-house brokerages)
• Any “customs packet” the carrier left with the delivery (sometimes contains a 7501)
• Your AP records (duty invoices often contain entry numbers or broker file numbers)

If you’re trying to request older entry documentation, recordkeeping rules generally require many entry-related records to be retained for 5 years from the date of entry (with some exceptions). (19 CFR 163.4)

Copy/paste request template (broker/carrier)

Subject: Request for CBP Form 7501 (Entry Summary) + Entry Numbers — [Your Company] — [Date Range]

Body:

• Legal company name: [Name]
• EIN / importer number (if known): [EIN]
• Date range: [Start] to [End]
• Shipment identifiers: [Tracking/AWB/BOL + invoice/PO numbers]
• Request: Please provide CBP Form 7501 (Entry Summary) PDFs for all entries in this range (including any continuation sheets), and provide a list of the entry numbers and the Importer of Record (IOR) shown on each entry.

5) What we still don’t know (keep this page honest)

This page should be updated as CBP and the government issue new guidance. As of the “Last verified” date above:

• The general legal/procedural framework (liquidation → protest timing) is clear in statute and CBP guidance. (CBP — Protests, 19 U.S.C. §1514)
• Operational details (templates, batching mechanics, processing timelines) may evolve and should be treated as “current guidance,” not permanent truth.
• Carrier/brokerage logistics may differ: if a carrier/brokerage was the IOR and advanced duties, the government refund (if any) may be paid to that party first, with pass-through to customers depending on the carrier’s process and terms. (See: FedEx alert — Feb. 24, 2026, FedEx — U.S. tariffs impact)

6) Frequently asked questions

Do I need a lawyer?

CBP protest filings do not inherently require a lawyer, but facts and strategy can be complex. If you’re unsure about standing, deadlines, or how to frame a claim, consult trade counsel.

Is there a single global deadline for everyone?

Generally, no — the protest statute uses 180 days after liquidation as the core clock. (19 U.S.C. §1514)

Can I file a protest before liquidation?

The general rule is tied to liquidation: a protest “shall be filed … within 180 days after but not before” the date of liquidation or reliquidation (with a separate rule where liquidation is inapplicable). (19 U.S.C. §1514)

What if I’m the buyer/consignee but not the IOR?

Confirm who is shown on the entry papers first (7501/ACE data). Depending on the facts, you may need IOR authorization/cooperation, or you may fit another “party in interest” category under the protest statute. (19 U.S.C. §1514)

What is “liquidation,” in plain English?

Liquidation is the process by which CBP “finalizes” an entry’s duty assessment, within a statutory framework that includes extensions/suspensions. (19 U.S.C. §1504)

What is a PSC?

CBP describes a Post Summary Correction (PSC) as the method to electronically correct entry summaries prior to liquidation in ACE, with specific eligibility and timing criteria. (CBP — Post Summary Corrections)

Can I file a protest electronically? Can I still file a paper protest?

Yes. CBP explains how protests are managed through the ACE Portal (including setting up a protest filer account), and states paper protests are still supported. (CBP — Protest (ACE guidance))

How far back can I request 7501s / entry documents?

It depends on the party, the document type, and the facts. As a general baseline, CBP’s recordkeeping rules include a 5-year retention period for many entry-related records (with specific exceptions for some record types and situations). Practically, older records are often still retrievable, but you usually need strong identifiers such as entry numbers, tracking/AWB/BOL references, invoice numbers, and date ranges. (19 CFR 163.4)

Does the “ending IEEPA collection” guidance also end my section 232 / section 301 exposure?

No. CBP’s CSMS guidance is explicit that the relevant Executive Order affects IEEPA duties only and “does not affect any other duties,” including section 232 and section 301 duties. (CBP CSMS #67834313)