The Supreme Court struck down $175 billion in IEEPA tariffs. You know you're owed money. But how much? Here's exactly how to identify your affected entries, separate IEEPA duties from other tariffs, and calculate your total refund amount.
Every importer who paid IEEPA tariffs between February 2025 and February 2026 is entitled to a refund. The Supreme Court was clear: those tariffs were collected without legal authority.
But "you're owed a refund" and "here's exactly how much" are two very different statements. Most importers have no idea what their actual IEEPA exposure is. The duties were stacked on top of existing Section 301 and Section 232 tariffs. They were assessed under dozens of different Chapter 99 HTS codes. And they changed constantly — rates shifted, countries were added, exemptions came and went.
If you don't know your number, you can't file the right claims. And you certainly can't tell your CFO what to expect.
This guide walks you through the exact process of identifying every IEEPA dollar you paid, separating it from duties that are still owed, and calculating your total potential recovery.
Why Calculating Your Refund Is Harder Than It Sounds
IEEPA tariffs didn't exist in a vacuum. A single shipment from China might have been subject to the base MFN duty rate, Section 301 tariffs at 25%, Section 232 tariffs on certain materials, and IEEPA tariffs on top of everything else. Only the IEEPA layer is refundable.
Making it more complicated, the IEEPA tariff regime changed at least eight times between February 2025 and February 2026. Rates went up. Rates paused. Country-specific rates replaced the universal baseline. Exemptions were added and removed. Each change created a different duty calculation for the same product depending on when it entered the country.
If you imported goods from China in March 2025, you might have paid 10% IEEPA. If you imported the same goods in August 2025, you might have paid a country-specific reciprocal rate under a completely different HTS code. Both are refundable — but at different amounts, under different codes, through potentially different processes.
Step 1: Pull Your Complete Entry Data from ACE
Log into the ACE Secure Data Portal and pull a comprehensive report of all entries filed between February 4, 2025 (when the first IEEPA tariffs on Canada, Mexico, and China took effect) and February 24, 2026 (the last day IEEPA tariffs were collected).
For each entry, you need:
- Entry number and entry date
- Liquidation status (unliquidated, liquidated, or suspended) and liquidation date if applicable
- All HTS line items, including Chapter 99 secondary classifications
- Duty amounts broken down by tariff program
- Country of origin for each line item
- Customs value (the declared value used as the duty base)
If you use a customs broker, request this data in a structured format — spreadsheet or CSV. Most broker platforms can generate IEEPA-specific duty reports. If yours cannot, you will need to filter manually.
Step 2: Identify IEEPA-Specific HTS Codes
IEEPA tariffs were assessed under Chapter 99 of the Harmonized Tariff Schedule. Specifically, all IEEPA tariff codes fall under subheadings beginning with 9903.01 and 9903.02.
Here are the key codes to look for:
Fentanyl / Immigration IEEPA Tariffs (February 2025)
| HTS Code | Description | Rate |
|---|---|---|
| 9903.01.01 | China/HK/Macau fentanyl tariff | 10% (later increased) |
| 9903.01.02 | Canada fentanyl tariff | 25% |
| 9903.01.03 | Mexico fentanyl tariff | 25% |
Reciprocal IEEPA Tariffs (April 2025 Onward)
| HTS Code | Description | Rate |
|---|---|---|
| 9903.01.25 | China/HK/Macau reciprocal tariff | 10% |
| 9903.01.26 | Canada exception (USMCA-qualifying goods) | Exempt |
| 9903.01.27 | Mexico exception (USMCA-qualifying goods) | Exempt |
| 9903.01.28 | In-transit exception (loaded before April 5, 2025) | Exempt |
| 9903.01.30–33 | Various China/HK/Macau exclusions | Varies |
| 9903.01.63 | China-specific 34% rate | 34% |
Country-Specific Reciprocal Tariffs (August 2025 Onward)
| HTS Code Range | Description | Rate Range |
|---|---|---|
| 9903.02.01–9903.02.71 | Country-specific reciprocal tariffs | 10%–49% |
| 9903.02.19–9903.02.20 | EU-specific reciprocal tariffs | 20% |
Important: Codes 9903.01.26 and 9903.01.27 are exceptions — if your entries only show these codes, those specific shipments were exempt from IEEPA tariffs (typically USMCA-qualifying goods from Canada and Mexico). Don't include them in your refund calculation.
What Is NOT IEEPA (Not Refundable)
Do not confuse these with IEEPA duties:
- Section 301 codes (9903.88.xx series) — These are tariffs on Chinese goods authorized under a different statute. They remain in effect.
- Section 232 codes (9903.80.xx series) — Steel, aluminum, auto, and copper tariffs. These are unaffected by the ruling.
- Section 201 codes (9903.45.xx series) — Safeguard tariffs on solar cells and washing machines. Still in effect.
- Antidumping/Countervailing duties (AD/CVD) — These are assessed under entirely different authority and are not impacted.
Step 3: Calculate Refund Amounts by Entry
For each entry line with an IEEPA Chapter 99 code, your refund amount equals:
Refund = Customs Value × IEEPA Tariff Rate
For example:
| Entry | Product | Customs Value | IEEPA Code | IEEPA Rate | Refund Amount |
|---|---|---|---|---|---|
| 001-2025 | Electronics from China | $500,000 | 9903.01.25 | 10% | $50,000 |
| 002-2025 | Auto parts from Mexico | $200,000 | 9903.01.03 | 25% | $50,000 |
| 003-2025 | Furniture from Vietnam | $150,000 | 9903.02.45 | 10% | $15,000 |
| 004-2025 | Steel from Canada | $300,000 | 9903.01.26 | Exempt | $0 |
In this example, the total IEEPA refund would be $115,000. The Canadian steel entry is $0 because it was USMCA-exempt.
Stacked Tariff Example
Here is a real-world example of a typical China import with stacked tariffs:
| Tariff Layer | Authority | Rate | On $100,000 Customs Value | Refundable? |
|---|---|---|---|---|
| MFN duty | Permanent tariff schedule | 5% | $5,000 | No |
| Section 301 | Trade Act of 1974 | 25% | $25,000 | No |
| IEEPA reciprocal | Executive Order (IEEPA) | 10% | $10,000 | Yes |
| Total duty paid | 40% | $40,000 | ||
| Refundable amount | $10,000 |
In this example, you paid $40,000 in total duties but only $10,000 is refundable — the IEEPA portion. The remaining $30,000 in MFN and Section 301 duties are still legally owed.
For China imports that were subject to the higher 34% IEEPA rate under 9903.01.63, or country-specific reciprocal rates above 10%, the refundable amount will be correspondingly higher.
Step 4: Build Your Refund Tracking Spreadsheet
Create a master spreadsheet with the following columns:
- Entry Number
- Entry Date
- Country of Origin
- HTS Code (Chapter 1–97)
- Chapter 99 IEEPA Code
- IEEPA Tariff Rate
- Customs Value
- IEEPA Duty Paid (Customs Value × IEEPA Rate)
- Liquidation Status (Unliquidated / Liquidated / Suspended)
- Liquidation Date (if applicable)
- Refund Pathway (PSC / Protest / CIT)
- Filing Deadline
- Filing Status (Not Filed / Filed / Approved / Denied)
This spreadsheet becomes your single source of truth. Every claim you file — whether PSC, protest, or CIT action — should trace back to a row in this document.
Categorize by Refund Pathway
Sort your entries into three buckets based on liquidation status:
| Liquidation Status | Refund Pathway | Deadline |
|---|---|---|
| Unliquidated | Post Summary Correction (PSC) | 300 days from entry OR 15 days before liquidation |
| Liquidated (within 180 days) | CBP Protest (Form 19) | 180 days from liquidation date |
| Liquidated (past 180 days) | Court of International Trade lawsuit | 2 years from date tariffs were exacted |
Priority order: File PSCs first (fastest resolution), then protests (preserve your rights before deadlines expire), then assess CIT litigation for large exposures.
Step 5: Verify Your Numbers
Before filing any claims, double-check your calculations:
Cross-reference with CBP data. Your ACE entry summaries show the exact duty amounts assessed. Match your calculated refund amounts against the actual IEEPA duty lines on each entry summary.
Watch for rate changes. IEEPA rates changed multiple times. A China import in March 2025 might have been assessed at 10%, while the same product in September 2025 might have been at a different rate under a country-specific code. Use the rate that was actually assessed, not the rate you think should have applied.
Check for exclusions and exceptions. Some products were temporarily excluded from IEEPA tariffs. If an exclusion applied to your product during the period you imported it, the IEEPA duty may not have been assessed — meaning there is nothing to refund for that entry.
Confirm the importer of record. Refunds are paid to the IOR listed on the entry summary, not the party that economically bore the cost. If your company is not the IOR on certain entries, you cannot claim the refund directly from CBP. You may have contractual rights against the IOR, but that is a separate matter.
Step 6: Understand the Scale of What You're Owed
To put your refund calculation in context, here is what IEEPA tariffs looked like at the program level:
| IEEPA Program | Approximate Collections | Period |
|---|---|---|
| Fentanyl tariffs (Canada/Mexico/China) | ~$45 billion | Feb 2025 – Feb 2026 |
| Liberation Day reciprocal tariffs | ~$85 billion | Apr 2025 – Feb 2026 |
| Country-specific reciprocal tariffs | ~$45 billion | Aug 2025 – Feb 2026 |
| Total IEEPA collections | ~$175 billion | Feb 2025 – Feb 2026 |
If your company imports $10 million annually from China and paid a 10% IEEPA reciprocal tariff for 12 months, your refund is approximately $1 million. If you import from multiple IEEPA-affected countries, or if your products were subject to higher country-specific rates, the number could be significantly larger.
Common Calculation Mistakes to Avoid
Mistake 1: Including Non-IEEPA Duties
The most common error is including Section 301 or Section 232 duties in the refund calculation. Only duties assessed under IEEPA-specific Chapter 99 codes are refundable. If you file a protest or PSC claiming a refund for Section 301 duties, it will be rejected.
Mistake 2: Using the Wrong Customs Value
IEEPA tariffs were assessed on the customs value (transaction value) of the goods, not the retail price or the total landed cost. Make sure you are using the declared customs value from the entry summary, not internal cost figures.
Mistake 3: Forgetting About Multiple Entry Lines
A single entry can have multiple line items with different HTS codes, different countries of origin, and different IEEPA tariff treatments. Calculate the refund for each line separately, then sum them for the entry total.
Mistake 4: Ignoring Partial Shipments and Amendments
If you filed post-entry amendments or PSCs before the ruling — for example, to correct a classification — the amended duty amounts are what matter, not the original filing.
Mistake 5: Double-Counting Entries Filed Under Multiple Programs
Some imports were subject to both fentanyl tariffs and reciprocal tariffs at different points in time. Make sure you are not double-counting entries that were amended or replaced as the program evolved.
What to Do With Your Calculation
Once you have your total IEEPA refund figure:
-
Share it with your CFO and finance team. This is a recoverable asset. Depending on the amount, it may need to be disclosed in financial statements or factored into cash flow projections.
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Prioritize your filings. Start with the highest-value entries and those closest to deadline expiration. A $500,000 entry with a protest deadline in 30 days takes priority over a $5,000 entry with 10 months remaining.
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Brief your customs broker. If your broker handles your CBP filings, give them the full spreadsheet and discuss the filing timeline. Many brokers are overwhelmed with IEEPA refund work right now — the earlier you engage, the better.
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Consider your contractual obligations. If you passed IEEPA tariff costs to customers through surcharges or price increases, consult with legal counsel about whether you have an obligation to pass refunds back. This is an emerging area of dispute.
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Verify your ACH banking information. As of February 6, 2026, CBP only issues refunds electronically via ACH. Log into the ACE Secure Data Portal and confirm your banking details are correct.
When to Bring in Professional Help
If any of the following apply, consider engaging a trade compliance specialist or customs attorney:
- Your total IEEPA exposure exceeds $500,000
- You have entries from multiple countries with different IEEPA rate structures
- Your entries involve stacked tariffs where separating IEEPA from Section 301/232 is complex
- You have entries that are past the 180-day protest window and may require CIT litigation
- Your company was not the importer of record but economically bore the tariff costs
For straightforward cases — single country of origin, consistent tariff rate, all entries clearly identified — most customs brokers can handle the calculation and filing process directly.
The Bottom Line
Calculating your IEEPA refund is not optional. It is the foundation for every filing you will make — PSC, protest, or CIT action. If your number is wrong, your claims will be wrong.
Pull your data. Identify every Chapter 99 code starting with 9903.01 or 9903.02. Separate IEEPA duties from everything else. Build your spreadsheet. Verify your numbers. Then file.
The money is yours. But only if you can prove exactly how much.
TariffLens helps importers identify duty exposure across every tariff program — IEEPA, Section 301, Section 232, and more. When you need to separate what's refundable from what's still owed, accuracy matters. See how TariffLens can help.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. Tariff regulations and refund procedures are evolving rapidly; verify current requirements with CBP official guidance and qualified trade counsel before making compliance decisions.