How to Calculate Your IEEPA Tariff Refund After the Supreme Court Ruling

If you imported goods from China, Russia, or other IEEPA-targeted countries between 2018 and February 20, 2026, you may be owed a refund. The Supreme Court's February 20, 2026 ruling invalidated the executive authority used to impose those tariffs. CBP has not yet announced a universal refund mechanism, but importers who acted under protest, filed for liquidation extensions, or have open entries have a clear path to recovery.

This guide walks through the calculation methodology, the documentation CBP will require, and where Triangle Trade Intelligence can help you get the numbers right before you file.

What the Supreme Court Ruling Actually Said

The Court found that the International Emergency Economic Powers Act (IEEPA) does not grant the President authority to impose tariffs as an economic emergency measure. The ruling does not affect Section 301 tariffs (China technology lists), Section 232 tariffs (steel and aluminum), or any tariffs authorized by Congress directly. Those remain in effect.

What is now invalid: the IEEPA reciprocal tariffs imposed on most countries starting in early 2025, the IEEPA fentanyl-related tariffs on China, Canada, and Mexico, and any other IEEPA-specific surcharges layered on top of existing Section 301 or MFN rates.

What is NOT affected by the ruling:

• MFN (Most Favored Nation) base rates
• Section 301 List 1, 2, 3, 4A tariffs on Chinese goods
• Section 232 steel and aluminum tariffs
• Section 122 tariffs (active, effective February 24, 2026)
• Any tariff enacted by Congress

This distinction matters enormously for your refund calculation. You cannot claim back Section 301. You can only claim back the IEEPA portion of your duty stack.

Step 1: Pull Your Entry Summary Records

CBP Form 7501 (Entry Summary) shows the breakdown of duties paid per entry. You need entries filed during the period when IEEPA tariffs were active. In general, review all entries from 2025 onward where IEEPA-specific HTS Chapter 99 codes appear.

Look for Chapter 99 special tariff codes like:

• 9903.01.XX series (IEEPA reciprocal tariffs)
• 9903.01.33 (note: Section 232 products were explicitly excluded from IEEPA reciprocal under this provision)

If you used a licensed customs broker, they have your CF-7501s on file. Pull at minimum 36 months of entry summaries. Many importers are surprised to find IEEPA codes they did not realize were applied.

Step 2: Separate the IEEPA Layer from Your Total Duty Stack

This is where most importers make mistakes. The IEEPA rate was applied on top of other rates, but it was NOT additive to Section 232 products. The stacking rules matter.

For a typical China-origin steel product: Section 232 products were excluded from IEEPA reciprocal per 9903.01.33. The refundable IEEPA amount on these goods is $0.

For a China-origin electronics product: the IEEPA fentanyl-related surcharge was applied on top of the base MFN and Section 301 rates. The full IEEPA portion on entered value is potentially refundable.

For a Mexico-origin industrial part qualifying under USMCA: if the IEEPA fentanyl rate was applied before the SCOTUS ruling, that amount on entered value may be refundable.

The math gets complex when you have hundreds of entries across different product categories, origin countries, and applicable policy lists. That is exactly what the IEEPA Refund Estimator is designed to handle.

Step 3: Calculate Entered Value by IEEPA-Eligible Entry

The refund is based on entered value, not selling price. Entered value is typically the transaction value declared on your import documentation, which should match the commercial invoice amount. Do not use the customs value if adjustments were made for assists, royalties, or other additions under 19 CFR Part 152.

For each eligible entry:

• Confirm the entered value from CF-7501, Box 34
• Confirm the applicable IEEPA rate for that HTS code and country of origin
• Calculate: entered value multiplied by IEEPA rate = refund amount per entry
• Sum across all eligible entries

A $500,000 per year importer of China-origin consumer goods with a 10% IEEPA rate on all goods could be looking at $50,000 in refundable duties, before interest. CBP pays interest on duties paid under protest at the 90-day Treasury bill rate.

Step 4: Determine Your Filing Method

There are three paths depending on your entry status:

• Path A (Entries Under Protest): If your broker filed a protest at the time of entry noting IEEPA-applicability, those entries are already in CBP's queue. The SCOTUS ruling strengthens your position significantly. Work with a licensed customs attorney to update the protest with the case citation.
• Path B (Unliquidated Entries): If entries are still unliquidated, you can request the IEEPA portion be removed before liquidation. This is a cleaner path than refund after liquidation.
• Path C (Post-Liquidation Refund): The most common situation and the most complex. File CBP Form 19 (Protest) within 180 days of liquidation. For entries that liquidated more than 180 days ago, you may be out of the protest window. Check liquidation dates in CBP's ACE portal.

What Documentation CBP Will Want

Regardless of path, prepare:

• Original commercial invoices with unit pricing and total value
• Bills of lading and airway bills confirming origin
• CF-7501 Entry Summaries with duty breakdown
• If claiming country of origin: certificates of origin or manufacturer declarations
• If claiming FTA treatment: USMCA certification or equivalent

CBP may request additional substantiation if the IEEPA rate classification is disputed. For products that straddle multiple tariff lists, having an HS classification audit trail showing GRI-based reasoning significantly strengthens your position.

How to Use the IEEPA Refund Estimator

Triangle Trade Intelligence built the IEEPA Refund Estimator specifically for this calculation. Enter your HS code, country of origin, entered value, and entry date. The tool:

• Identifies whether IEEPA was applicable to that HS code and origin during the entry period
• Confirms whether any stacking exclusions applied (Section 232 products, USMCA-origin goods)
• Calculates the refundable IEEPA amount
• Returns the Federal Register citation and policy source for your documentation

The calculator uses the same database that powers our API, with 110,000+ tariff records and historical IEEPA rates preserved exactly as they were active. This gives you a defensible, citation-backed calculation rather than a rough estimate.

A Few Cautions

The refund landscape is still developing. CBP has not issued formal guidance as of early March 2026. Congressional action or executive response to the SCOTUS ruling could change the refund mechanism. Work with a licensed customs attorney or customs broker for actual filings. The Refund Estimator gives you the numbers to inform that conversation, not replace it.

Section 122 tariffs (the 10% global surcharge that went active February 24, 2026) are a separate authority and are NOT refundable. Do not confuse Section 122 with IEEPA. They look similar (both are percentage-based surcharges) but Section 122 has explicit Congressional authority under 19 U.S.C. 2132. That is the key legal distinction.

For importers with significant China exposure, this refund opportunity is real and the window is time-limited. Start with your entry summaries, run the numbers through the estimator, and get a customs attorney involved early.