IEEPA Tariff Refunds: Do You Qualify, and How Much?

The Supreme Court struck down IEEPA tariffs in February 2026. If you paid them in 2025, you may be owed a refund — plus interest. Estimate your exposure in under a minute, then take the number to your broker.

Estimate My Refund →

On February 20, 2026, the Supreme Court ruled 6–3 in V.O.S. Selections, Inc. v. United Statesthat IEEPA does not authorize the President to impose tariffs. Every IEEPA “reciprocal” and “fentanyl” tariff collected between April 2025 and February 2026 is now eligible for refund. CBP opened its refund portal (CAPE) on April 20, 2026. Roughly $166 billion was collected from over 330,000 importers — about 82% of it, ~$127 billion including statutory interest, is eligible in the first phase. If you paid an IEEPA tariff in 2025, the money is recoverable. The question is which of your entries qualify now, and which have to wait.

What’s refundable — and what is NOT

Refundable — struck down by the Supreme Court:

  • IEEPA “reciprocal” tariffs (10% baseline plus country-specific rates)
  • IEEPA “fentanyl / trafficking” tariffs on Canada, Mexico, and China
  • These carry Chapter 99 HTS codes beginning 9903.01 or 9903.02

NOT refundable — different legal authorities, still in force:

  • Section 232 (Annex I-A primary)50% primary metal tariff on full customs value for steel (Ch.72), aluminum (Ch.76), copper (Ch.74). 25% derivative tariff on full customs value for Annex I-B articles (Ch.73 steel articles and metal content in other chapters). National security authority, untouched by the ruling.
  • Section 301 (China tariffs)Section 301 tariff applies to China/Hong Kong-origin goods at the rate set by the applicable USTR List or 2024 four-year review modification. Separate trade authority, untouched by the ruling.

NOT refundable, and no longer charged — Section 122 (10% broad-based):

10% broad-based tariff on most US imports expired 2026-07-24 (9903.03.01). It was a separate authority from IEEPA, so amounts collected under it while it was in force are not part of an IEEPA refund claim, and no Section 122 duty is being charged on entries today.

If your 2025 entries stacked IEEPA on top of Section 301, only the IEEPA layer refunds. The Section 301 duty stays owed. Getting that split right on every entry is the whole game.

Which entries qualify now

Phase 1 (open now): unliquidated entries; entries within 80 days of liquidation.

Not yet in Phase 1: older liquidated entries wait for a later phase.

Entries liquidate on a rolling basis — the window on specific entries can be closing now. Liquidation status drives priority, not the total you paid.

Estimate your exposure

Triangle’s IEEPA Refund Estimator separates the layers. Enter your product origin and import value, and it estimates the IEEPA duty that’s now recoverable versus the tariffs that remain in force — and checks whether each entry is still eligible based on its liquidation status. You walk into the refund conversation with a defensible number, not a guess.

Estimate My Refund →

Triangle provides analysis, not filing services or legal advice. Refund claims are filed through CBP by the Importer of Record or a licensed customs broker. Verify every entry with your broker before filing.

Frequently Asked Questions

Are IEEPA tariff refunds automatic?

No. The Supreme Court invalidated the tariffs but did not order automatic refunds. The Importer of Record or an authorized customs broker must file a claim through CBP's CAPE system in the ACE portal. Refunds on accepted claims are generally issued within 60–90 days.

Can I get a refund on Section 301 or Section 232 tariffs?

No. Only IEEPA tariffs were struck down. Section 301 and Section 232 are separate legal authorities and remain in force: Section 301 tariff applies to China/Hong Kong-origin goods at the rate set by the applicable USTR List or 2024 four-year review modification. 50% primary metal tariff on full customs value for steel (Ch.72), aluminum (Ch.76), copper (Ch.74). 10% broad-based tariff on most US imports expired 2026-07-24 (9903.03.01). Its lapse is not an IEEPA refund either — it was a different authority, so amounts collected under it are outside an IEEPA claim.

How do I know if my entries had IEEPA duties?

Check your entry summaries for Chapter 99 HTS codes beginning with 9903.01 or 9903.02.

Who can file the refund claim?

Only the Importer of Record, or a licensed customs broker authorized to act on the IOR's behalf, can submit a claim through CBP's ACE portal.

Does the refund include interest?

Yes. CBP refunds of validated IEEPA duties include statutory interest from the original entry date.