Preparing for Potential IEEPA Tariff Refunds

As the Supreme Court weighs the legality of tariffs imposed under the International Emergency Economic Powers Act (IEEPA), importers should plan ahead. If these duties are overturned, companies with a strong compliance foundation will be best positioned to secure timely refunds by filing protests. 

Steps importers should take to maximize potential refunds and ensure timely recovery of duties: 

1. Obtain duty summary and entry-level reports from the Automated Commercial Environment (ACE). Refresh this dataset periodically to maintain a current and accurate accounting of total duties paid, in case refunds become available. 

2. Ensure accessibility to all required import documents, including complete entry packets, HTS and origin support files, and all other materials required under CBP’s recordkeeping standards. 

3. Begin preparing protests to recover IEEPA duties. If the tariffs are overturned, prompt filing will help ensure recovery. 

4. Consider filing protests in advance to accelerate potential refunds if the IEEPA duties are ultimately invalidated. Although CBP will not rule on the legality of the IEEPA at this point, the agency may hold these protests until the Court resolves the issue. 

5. Monitor liquidation dates for all applicable entries, keeping in mind the time requirements for protests (within 180 days of liquidation). 

6. Setup account to receive electronic refunds: In accordance with E.O.14247, CBP will transition from issuing paper refund checks to utilizing ACH to issue refunds. The ACE Portal has launched a new ACH Refund Authorization tab to help importers receive refunds. Paper checks will not be sent.  

In summary, taking the above steps will help the duty recovery process should the IEEPA tariffs be overturned.  

How Allyn International Can Help 

Allyn International can support importers at every step of this preparation. Our team can help you organize and standardize your documentation to create clean, refund-support files that tie together entry data, product information, and classification logic. When the legal landscape shifts, we can guide you through the refund process itself, from exposure analysis to claim preparation. 

If IEEPA tariffs are overturned, companies that start preparing now will be able to move quickly and confidently. Allyn is ready to help you build that foundation. Contact us today for a consultation at sales@allynintl.com, call 239-489-9900, or reach out here.