How manufacturers can pursue IEEPA tariff refunds
After the Supreme Court struck down the Trump administration’s International Emergency Economic Powers Act (IEEPA) tariffs, an estimated $166 billion has been designated for refunds.
If you are a manufacturing organization, you’ve almost certainly been impacted by tariffs, either directly or indirectly. Naturally, the possibility of getting some of that money back is enticing. But understanding how much of a refund your business may be eligible for and how to claim it can be confusing.
Discover how to determine your eligibility and how to file for a refund.
Are the tariffs you paid eligible for a refund?
Only one type of tariff is eligible for refunds: IEEPA tariffs. These tariffs were implemented in February 2025, early in Trump’s second term. IEEPA tariff rates fluctuated until the Supreme Court ruled that the law did not grant the president authority for broad tariff actions in February 2026.
Any duties paid under these other four tariffs are not eligible for a refund at this time:
- Most Favored Nation (MFN) tariffs: These are the “baseline” duties set under the U.S. Harmonized Tariff Schedule (HTS). They apply to most imports from countries without special trade agreements and represent the standard cost of importing goods.
- Section 301 tariffs: These tariffs were imposed during Trump’s first term. They are imposed primarily on goods from China. The administration is considering imposing additional Section 301 tariffs in response to the IEEPA tariffs being struck down.
- Section 232 tariffs: These tariffs apply to specific industries tied to national security — most notably steel, aluminum and certain derivative products. Similar to section 301, the administration is also pursuing investigations to impose tariffs on additional industries or goods.
- Section 122 tariffs: Following the IEEPA ruling, a temporary global tariff under Section 122 took effect on February 24, 2026. They apply broadly but are limited to 150 days, meaning they will expire in late July 2026. Unlike Section 232 and 301, these tariffs have not been upheld by the Court of International Trade and the U.S. Supreme Court, which means they could also be struck down by the courts and refunds could be issued.
What should importers of record do to get a refund?
To be eligible for a refund from the government, your business must be the importer of record. Your business is the importer of record if:
- Your company directly pays duties to Customs and Border Patrol (CBP) through Automated Clearing House (ACH) payments.
- You pay a broker to import goods on your behalf.
If your organization meets the criteria, these are the steps to pursue a refund:
1. Establish access to your ACE portal
Manufacturers seeking a refund must work with their customs broker to either establish or gain access to an Automated Commercial Environment (ACE) portal account. You will need your importer of record (IR) number to file for a refund.
The historical import information in your ACE portal is a good first step to understanding the potential ROI and IEEPA-specific tariffs paid, noted in the following steps.
2. Consider your ROI
Your business may be eligible for a refund, but that doesn’t mean it’s worth the effort. Think about how much money you paid in IEEPA tariffs and how difficult it will be to track down records dating back to the spring of 2025. If you’re looking at a significant amount of money and your records are readily available, then filing for a refund makes sense.
On the other hand, if you only paid a few thousand dollars in tariffs and it would take hours of manpower to pull the records, the return on investment might not be enough.
If your organization doesn’t have a system in place to quickly pull tariff data, remember that tariffs aren’t going away. It’s also likely we haven’t seen the last lawsuits over tariffs, meaning there could be more refunds in the future. Consider implementing a system to better organize tariff records so you’re better prepared if there’s another round of refunds.
3. Determine how much you paid for IEEPA tariffs
If you do want to pursue a refund, start by identifying which tariffs you paid were IEEPA duties. For most companies, this process is straightforward because the details can be found in your ACE portal for all tariffs you were the importer of record on.
If you are struggling to determine IEEPA specific tariffs paid, take the following steps:
- Ask your suppliers if they can provide invoices that include information on the amount of duties paid for specific tariffs.
- If your suppliers decline to provide the more detailed invoices, you can use Harmonized Tariff Schedule (HTS) codes and country of origin data to identify which tariffs were paid for goods. For businesses that import a small number of products from only a few countries, this will be a manageable process. Large operations that import dozens or hundreds of products from multiple countries will want to consider bringing in outside help, because this will likely be a complex task.
4. Prepare to file through ACE
CBP is processing IEEPA refunds through ACE and its CAPE refund functionality. Importers of record must follow CBP’s filing procedures and provide the required supporting documentation. The specific documentation requirements vary by the type and status of the import entries, making early preparation essential. Guidance on processes and documentation is available on the ACE portal.
What are the timelines for requesting a tariff refund?
Tariff refunds are being rolled out in phases. We are currently in phase 1, which allows businesses to file for refunds of tariffs paid that have not been fully liquidated or have been liquidated in the last 80 days. Specifics vary, but in general, this means IEEPA tariffs paid in the last 380 days are eligible for a refund filing in Phase 1. Phases 2 and 3 will allow businesses to file refunds for tariffs paid long ago or with more complex situations. There will be some additional complexities when filing in phases 2 and 3.
So while there is no filing deadline, if your organization wants to request a refund for a tariff that’s approaching the 380-day mark, it’s best to file soon.
Can non-importers of record get a tariff refund?
A non-importer of record is not directly eligible for a refund because they didn’t pay a tariff to the government. But that doesn’t mean they weren’t affected. There are many instances where the tariff costs were passed through supply chains, including:
- Retailers that stock imported products from domestic distributors or manufacturers.
- Manufacturers that buy steel, aluminum, electronic components, machinery or other materials from U.S.-based suppliers.
- Businesses that purchase equipment from domestic manufacturers whose products contain imported components.
If tariff expenses were passed on to your business, you may be able to recover some of the money from your suppliers.
Negotiate with your suppliers
Suppliers are not specifically obligated to share any refunds they receive. But to maintain good customer relationships, they may be willing to pay you back. It never hurts to ask.
Approach your suppliers with a well-laid-out case to be refunded for any tariff costs they passed along and make sure to be specific with IEEPA tariffs. It is likely that you paid multiple types of tariffs to your suppliers and only IEEPA tariffs are eligible for refunds at this stage.
Initiate the conversation with some questions about their refund plans:
- Have you filed for a refund, or do you plan on filing?
- How much of a refund are you expecting, or have you already received?
- Are you willing to refund us some of the money we paid you to cover tariff expenses?
- What are your reimbursement steps?
If a supplier is willing to refund some of the tariff costs, come to the negotiating table with tangible data. Be prepared to provide them with date ranges, invoice numbers and dollar amounts (avoid percentages if possible). A discussion with suppliers that centers on a documented refund amount is typically more effective.
How should suppliers handle customers requesting refunds?
If your business is an importer of record, you may hear from customers asking if you’ll provide any tariff refunds. Here are some strategies to respond to those inquiries and maintain good customer relations:
- Analyze your tariff data: Know what tariff costs you passed through to customers and whether those tariffs are eligible for a refund.
- Proactive communication: Don’t wait for your customers to reach out to you. Send an email saying you’re weighing refund options and analyzing next steps.
- Avoid blanket statements: You may not have charged the same fees related to tariffs to every customer, and you likely did not pay the same effective tariff rate on all goods imported. Avoid making generic promises when each account should be analyzed on a case-by-case basis.
Remember, your business is not obligated to share any refund money you get. If you only passed along a fraction of the tariff costs and absorbed most of the expense, refunds may not be the right decision. Assess how much money is lost, how much you’re getting back and determine what the best move is for your business and its customer relationships.
How Wipfli can help
Your business could have a complex tariff posture. Serving as the importer of record in some situations, while being passed along tariff costs by suppliers in other situations. We can help you assess what tariffs you have paid and your overall refund eligibility.
At Wipfli, we understand manufacturing operations. We can help your business identify cost-saving opportunities and efficiency improvements to counteract any margin erosion caused by tariffs. Start a conversation
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