Companies that have paid U.S. import tariffs under the International Emergency Economic Powers Act (IEEPA) may be entitled to a refund. Eligibility depends on the liquidation status of the customs entry and applicable U.S. Customs and Border Protection (CBP) deadlines. Businesses should review affected imports promptly to determine whether refund opportunities remain available.

Background

The tariffs introduced under IEEPA applied to a broad range of imports, including certain country-specific measures affecting goods originating from China, Canada and Mexico. As the legal basis for these tariffs has been challenged successfully, importers may have opportunities to seek reimbursement of duties paid to U.S. Customs and Border Protection (CBP). Given the potentially significant amounts involved, companies should review their customs data and determine whether affected imports fall within the scope of available refund procedures.

Understanding the refund process 

The appropriate refund mechanism depends on the status of the customs entry and whether the entry has been liquidated. Under U.S. customs law, liquidation is the process through which CBP makes its final determination of duties owed on an import entry. Once liquidation occurs, specific statutory deadlines apply for challenging the assessment and requesting a refund.

Entries not yet liquidated or recently liquidated

Where an entry has not yet been liquidated, or where action is taken within 80 days following liquidation, importers may be able to request a refund through an administrative procedure available via the CBP customs portal.

Entries liquidated more than 80 days ago

Where more than 80 days have passed since liquidation, a formal protest procedure is generally required. Importers typically have up to 180 days from the liquidation date to file a protest with CBP.

Why businesses should act now

• Imports that were subject to IEEPA duties
• Entries that remain eligible for refund claims
• Upcoming liquidation or protest deadlines
• Opportunities to recover historical customs costs

How Svalner Atlas can help

Unsure whether your business may be entitled to an IEEPA refund? Our Customs & International Trade specialists can help assess eligibility, identify filing deadlines and support CBP refund or protest procedures. Contact our team to discuss your situation.

Frequently asked questions 

What is an IEEPA tariff refund? 

An IEEPA tariff refund allows eligible importers to recover duties paid under tariffs imposed pursuant to IEEPA, subject to applicable CBP procedures and deadlines.

How do I know if my imports qualify?

Eligibility depends on the products imported, duties paid and the liquidation status of the customs entry. A review of customs data is typically required.

What is the deadline? 

The applicable procedure and deadline depend on whether the customs entry has been liquidated and how much time has passed since liquidation.

Can a customs protest be required? 

Yes. In certain situations, importers may need to file a formal protest with CBP to preserve refund rights.