The U.S. Supreme Court’s recent decision overturning tariffs imposed by the Trump administration under the International Emergency Economic Powers Act (IEEPA) creates valuable refund opportunities for importers that paid billions in now-invalidated duties. On March 12, 2026, U.S. Customs and Border Protection (CBP) filed a declaration with the U.S. Court of International Trade (CIT) outlining its proposed tariff refund process. While this guidance is helpful, importers should be prepared for additional procedural guidance and delays.
CBIZ is closely monitoring developments regarding the IEEPA tariff refund process to ensure our clients are ready on day one. The following summarizes recent developments and action items for importers.
Timeline
- Feb. 20: The U.S. Supreme Court released its decision in Learning Resources v. Trump. The decision held that the IEEPA does not authorize the president to impose tariffs. Notably, the Supreme Court did not address the issue of refunds.
- March 4: The CIT issued an order requiring a refund of IEEPA tariffs. Specifically, the CIT ordered the CBP to liquidate unliquidated entries without regard to IEEPA tariffs and to reliquidate, without IEEPA tariffs, any entries liquidated but not yet final. The ruling did not apply to final liquidated entries. More than 330,000 importers made over 53 million entries involving IEEPPA tariffs.
- March 6: During a non-public conference before the CIT, CBP outlined operational challenges associated with issuing immediate IEEPA tariff refunds. CBP estimated it would take up to 45 days to upgrade systems and develop a process. The CIT temporarily paused implementation of its March 4 order requiring immediate refunds and directed CBP to provide an update on its administrative solution.
- March 12: CBP filed a declaration with the CIT that outlines a proposed tariff refund process. The declaration describes several system upgrades, including a new module known as Consolidated Administration and Processing of Entries (CAPE). CAPE will be part of the current Automated Commercial Environment (ACE) system that tracks imports and processes tariff payments. CBP informed the CIT that the tariff refund process is more than 40% complete. Additional updates are expected over the next several weeks.
How CBIZ Can Help
Corporate tax and trade leaders should act swiftly to preserve refund claims while simultaneously developing resilient strategies to address the ongoing changes in tariff policies. Affected importers should be prepared to provide all required information to CBP.
In anticipation of the formal release of a proposed CBP refund program, our Tariff Solutions professionals can help you:
- Calculate and substantiate IEEPA tariffs.
- Assemble required documentation to support refund submissions including country of origin, valuation, and HTS Code classification.
- Review your transfer pricing models and relevant agreements to identify the parties entitled to the refund proceeds.
- Ensure compliance with the CBP enrollment process, including ACE registration.
- Understand and implement new regulatory guidance regarding IEEPA tariff refund procedures.
- Comply with financial accounting and tax rules resulting from the Supreme Court decision and IEEPA tariff refunds.
Bear in mind that this ruling only affects tariffs imposed under IEEPA. Tariffs imposed under other trade laws remain in effect. In response to the Supreme Court ruling, President Trump has already invoked Section 122 of the 1974 Trade Act to temporarily impose a 10% global tariff, which took effect on Feb. 24, 2026. Multiple lawsuits have been filed challenging the Section 122 tariffs. While these cases work through the court system and the IEEPA refund process is developed, clients should continue to proactively implement broader tariff mitigation strategies.
CBIZ Tariff Solutions provides tools to measure the impact of tariffs on pricing, costs, and inventory. Mitigation strategies include:
- Supply Chain Optimization
- Valuation and classification support
- Financial & Tax Strategies
- Transfer Pricing
- Compliance & Advisory
Contact Us
Contact our Tariffs & Trade Team Leaders for information about IEEPA tariff refunds or measuring tariff impacts. We will continue to keep you informed about new developments.
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