IEEPA Tariffs Are Dead. Here's How to Find Out What You Overpaid.

On February 20, 2026, the Supreme Court struck down IEEPA tariffs. If you've been paying them (and most US importers have), you may be owed a refund. The problem: most companies have no idea what they actually paid under IEEPA versus their other tariff layers, and the window to file claims is not going to stay open forever.

This post explains what happened, what it means for your landed costs, and how to calculate your potential refund in about 60 seconds.

Update, August 5, 2026: the Section 122 tariff this post describes as the replacement for IEEPA has itself expired. Its 150-day authority lapsed on July 24, 2026 and Congress did not extend it. What took its place is a Section 301 forced-labor action, and it does not work the same way — USMCA partners are not exempt from it. Treat the Section 122 descriptions below as a record of what applied between February 24 and July 24, 2026. The IEEPA refund guidance is unaffected.

What the Supreme Court Actually Ruled

The Court found that IEEPA (the International Emergency Economic Powers Act) did not grant the executive branch authority to impose broad tariff schedules. The ruling effectively invalidated the IEEPA reciprocal tariff framework that had been adding 10-25% (and in some cases higher) on imports from dozens of countries, with China bearing the highest rates.

The ruling came down February 20. By February 24 a replacement was already in force: the President invoked Section 122 of the Trade Act (Proclamation 11012 of February 20, 2026), which imposes a flat 10% global tariff, but with two critical exemptions that change the math significantly for many importers.

Section 122 Replaced IEEPA. But It's Not the Same Thing.

Here's what the new Section 122 tariff looks like as of February 24, 2026:

• Rate: 10% flat on most imports
• Expiration: July 24, 2026 (150-day authority)
• Exempt: USMCA partners. If your goods are manufactured in Mexico or Canada and qualify under USMCA rules of origin, Section 122 does not apply.
• Exempt: Products already subject to Section 232 (steel, aluminum, and their derivatives)

That USMCA exemption was significant while it lasted. Under IEEPA, Mexico-origin goods that qualified under USMCA were still subject to IEEPA fentanyl tariffs (25%) on top of USMCA preferential rates. Under Section 122, USMCA-qualified goods were fully exempt. The Section 301 forced-labor action that replaced Section 122 on July 24, 2026 carries its own USMCA exemption (heading 9903.05.94), but it is narrower: it applies only where the good is USMCA-qualified and enters free of duty, and it does nothing for an article inside Section 232 scope, which pays 25% however well it qualifies.

How to Calculate Your IEEPA Refund

The refund calculation is not straightforward because IEEPA rates varied by country and product, and they interacted differently with Section 301 and Section 232 depending on what you were importing and where from.

Triangle's free IEEPA Refund Estimator does the calculation for you. Enter your HS code, origin country, annual import value, and the period you were subject to IEEPA tariffs. It returns:

• Your estimated IEEPA tariff paid over the period
• The portion attributable to fentanyl surcharges vs. reciprocal tariffs
• An estimate of what's potentially reclaimable
• The tariff stack comparison: what you paid then vs. what you'd pay under Section 122 now

No signup required. Free, takes about 60 seconds.

What to Do Right Now

If you import from China: Your tariff stack changed, but not dramatically. Section 301 rates remain. IEEPA is gone and replaced by Section 122 (10%). The net change depends on your specific HS code and whether you have active Section 301 exclusions.

If you import from Mexico and you're USMCA-qualified: your tariff burden dropped materially while Section 122 was in force, because USMCA partners were exempt from it. Section 122 ended on July 24, 2026 and its successor exempts USMCA-qualified goods on narrower terms (heading 9903.05.94). Outside Section 232 scope a qualifying Mexican good is still 0%; inside it, Section 232 stands at 25% no matter how well the good qualifies. Which of those two you are is the question worth answering before you model anything.

If you import from non-FTA countries other than China: You went from IEEPA reciprocal rates (which varied from 10% to 46% depending on country) to Section 122 at a flat 10%. That could be a reduction or roughly the same depending on where you were.

For the precise numbers on your HS codes, run the calculation below.