Letter from the CEO: IEEPA Tariff Refunds, Liquidation, and What Importers Should Know
There was a lot packed into this week. CBP rolled out guidance on the temporary 10 percent Section 122 surcharge, and at the same time officially stopped collecting certain IEEPA duties after the Supreme Court decision. On paper, one duty ends and another begins. In practice, it is not that simple.
There has been a lot of discussion around potential refunds for the IEEPA tariffs after the Supreme Court decision. The latest move by the Court of International Trade gives some direction, but it also makes clear that the process will not be simple.
For entries that have not yet liquidated, refunds may eventually be issued on duties that were paid. For others where duties were estimated but not yet collected, those charges could be removed when the entry is finalized. But that does not mean the process will be automatic or quick.
The bigger challenge involves entries that have already liquidated with IEEPA duties applied. That is where protests, additional legal action, and whatever refund mechanism ultimately emerges will matter most. There is also a strong possibility the ruling will be appealed, which could delay things further.
For importers, this is really about preparation. Liquidation timelines, protest deadlines, and entry documentation will all play a role if refunds move forward.
It also reinforces why duty drawback continues to matter. Companies exporting goods that were subject to tariffs may have an opportunity to recover duties through drawback while the broader refund process continues to take shape.