IFPA releases IEEPA tariff refund update

Last month, the U.S. Supreme Court ruled that certain tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were illegal.

This means, many U.S. importers will be able to seek refunds on duties they previously paid.

The International Fresh Produce Association BB #:378962 released guidance for members seeking the refunds, and it scheduled a webinar for members on the topic for March 11.

A March 4, 2026 order from the U.S. Court of International Trade is the first step toward tariff reimbursements.

On March 6, 2026, U.S. Customs and Border Protection informed the Court of International Trade that it is preparing a system to process refunds of collected IEEPA tariffs without requiring importers to file individual lawsuits.

IFPA says the Trump administration is expected to challenge the order in the courts, and it will monitor CBP implementation and legal developments and will provide additional guidance as the refund process becomes clearer.

IFPA released a guide on what importers should know:

Who May Be Eligible for Relief

• Importers of record who directly paid IEEPA based tariffs
• Consignee that took ownership of goods after customs clearance
• Businesses that did not directly pay the tariffs are not eligible.

Tariffs Not Covered

• Section 122, Section 232, Section 301, Section 201 tariffs
• Anti dumping and countervailing duties (AD/CVDs)
• Most favored nation (MFN) duties

What This Means for Members

• IEEPA tariffs should no longer apply to covered entries as U.S. Customs and Border Protection (CBP) begins implementing the court’s order.
• Refund procedures have not yet been announced, including timing, interest, and treatment of finalized entries.
• Importers should begin reviewing their records now to determine whether they paid IEEPA-based duties.

When working with a customs broker, you should ask

• What tariffs did I pay that were assessed under IEEPA?
• What records do I need to provide to substantiate a tariff refund?
• What specific records must be assembled (entry summaries, ACE reports, invoices, classifications, country-of – origin support)?
• How should we calculate potential refund amounts?