Trump Tariff Refunds: $166 Billion Owed, and Most Importers Aren't Ready

The Supreme Court struck down the Trump administration's IEEPA tariffs, and CBP now owes roughly $166 billion back to importers who paid duties from February 2025 through February 2026. CBP says the refund system will require minimal effort from importers, but there's real prep work that shouldn't wait. Here's where things stand and what finance teams should handle now.

What happened

On February 20, 2026, the Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that IEEPA (the International Emergency Economic Powers Act) doesn't give the president authority to impose tariffs. The Trump tariffs struck down by the court include both the reciprocal and fentanyl tariff programs, covering roughly 330,000 importers, 53 million entries, and $166 billion in collected duties that now have to be returned, with interest.

Court of International Trade Judge Richard Eaton then ordered CBP to begin refunding immediately in the Atmus Filtration case, calling the duties unlawful from the moment they were imposed. The legal question is resolved, but the mechanics of actually returning the money are not.

Trump's replacement tariffs are already in effect

The IEEPA tariffs are dead, but the Trump administration moved fast. Replacement tariffs under Section 122 of the Trade Act of 1974 went into effect the same week, starting February 24 for 150 days, and a group of states is already suing to block them. On top of Section 122, these tariffs were never part of the IEEPA case and still apply:

• Section 301 tariffs: Duties on Chinese goods that predate the IEEPA emergency orders.
• Section 232 tariffs: Steel and aluminum duties that remain in effect regardless of the ruling.

Importers may get IEEPA money back, but the tariffs that remain in effect mean forward costs are still elevated. Pricing models, working capital projections, and vendor negotiations all need to reflect both realities at once.

Why refunds aren't flowing yet

CBP's systems weren't built for this. Processing 53 million entries one by one would take over 4.4 million staff hours, so CBP asked the court for 45 days to build an automated system that consolidates refunds per importer. The target launch is April 20, 2026, and the court agreed to pause its immediate compliance order while CBP builds it.

The agency says the new system will need minimal input from importers since CBP already has electronic records of every IEEPA payment. That's encouraging, but companies that have switched brokers, gone through acquisitions, or have multiple importer numbers on file should expect more friction than most.

Most importers can't receive refunds yet

CBP switched to electronic-only refunds via ACH on February 6, 2026, but only about 21,400 of 330,566 eligible importers have actually enrolled. That's roughly 6.5%, which means the vast majority of companies owed money have no way to receive it right now. Unenrolled importers simply won't get paid, even if their refund is approved on CBP's end.

Enrollment happens through the ACE Portal using your importer TIN and a U.S. bank account. For growth-stage companies that don't have a dedicated trade compliance team, this often falls to whoever owns the finance function, and it needs to happen before the April 20 system goes live.

Don't count this as cash yet

Even if CBP's system launches on time, the gap between "processed" and "deposited" could stretch months, especially for entries that have already been liquidated and need formal protests. If you run a rolling 13-week cash flow forecast, treat the refund as upside rather than baseline. Putting uncertain refund money into near-term projections creates exactly the kind of cash flow surprise these forecasts are supposed to prevent.

For board reporting, keep refunds out of your base case until the system is live and your entries qualify. The action items below cover how to verify that.

Who actually gets the refund

Under U.S. customs law, refunds go to the Importer of Record (IOR), the company that legally filed the customs entry and paid the duties. If you buy from a U.S. distributor that was the actual IOR, there usually isn't a direct CBP claim for the downstream buyer, even if you absorbed the cost through higher prices.

That said, supply agreements often contain tariff clauses, price adjustment provisions, or cost pass-through language that determines who keeps refund value. If your contracts are silent on this, expect disputes once money starts moving. For companies that raised prices during the IEEPA period, the margin analysis and customer conversations are worth getting ahead of now.

What finance teams should be doing this week

The refund system is expected to launch in roughly five weeks. CBP's own declaration identifies specific steps importers should take now, and we'd add a few for finance teams specifically:

• Enroll in ACH refunds: This is the gating item. Complete enrollment in the ACE Portal with U.S. bank account information tied to your importer's TIN/SSN. If you have multiple EIN plus suffix combinations (Form 5106 records), each one needs separate enrollment. Without this, refunds get rejected regardless of whether they've been approved.
• Set up an ACE Top Account: Many importers assume that having an IOR number gives them portal access, but it doesn't. This requires submitting a separate Top Account application linking the IOR number to an ACE profile, which provides direct access to trade data instead of relying on a broker to pull it.
• Inventory your IEEPA entries: Ask your customs broker for all entry summaries (CBP Form 7501) from February 2025 through February 2026 and isolate entries with Chapter 99 HTSUS codes (9903.01.xx or 9903.02.xx). Build a tracker covering entry number, date, IEEPA amount, and liquidation status, since clean data is required to file a declaration in ACE once the system is live.
• Watch liquidation dates and file protests now if needed: Entries are liquidating on the normal 314-day cycle right now, and once liquidation becomes final, the 180-day window to file a protest starts closing. Entries from early 2025 may already be past this point. If your broker isn't tracking these deadlines, that's a conversation to have this week.
• Review the accounting and tax implications: Refunds plus interest affect your books in ways that aren't obvious, from how you value inventory that was imported under IEEPA duties to how you report the interest as taxable income. Finance teams should loop in their accountants or auditors now rather than scrambling when money arrives.

We'd also recommend modeling a few refund scenarios for cash flow planning: refunds on the expected timeline, delays pushing receipts into late 2026, or complications reducing the recoverable amount. Each one hits working capital, inventory costing, and procurement negotiations differently.

Tracking tariff exposure across your systems

Filing for refunds is only part of the problem for mid-market importers. The harder part is figuring out where tariff costs are buried across your books. The practical setup is three sources that need to reconcile: broker entry-level exports confirming IEEPA duty amounts and liquidation status, an internal tracker tying each entry to purchase orders and inventory lots so finance can trace duties through COGS, and your accounting or expense management system reconciling broker statements against GL coding.

When those three sources agree, refund work becomes reconciliation instead of detective work. Your customs broker is the most important relationship here since they hold the entry-level detail and will likely handle the ACE declaration filing on your behalf. Smaller importers without a dedicated compliance function will typically file through their broker rather than running a standalone workflow for a one-time event.

Frequently asked questions about Trump tariff refunds

How long will tariff refunds take to process?

CBP's automated system is expected to launch around April 20, 2026. Straightforward refunds on unliquidated entries may move faster, while liquidated entries requiring formal protests could take significantly longer. The court ordered refunds with interest, but the timeline for actually receiving payments is still uncertain, so plan conservatively.

Are the new Section 122 tariffs legal?

That question is already in court. For planning purposes, assume they're in effect until a court says otherwise, while keeping a contingency model in case they're struck down too.

Should companies roll back price increases after receiving refunds?

This is a business decision, not a legal requirement. Landed costs under the replacement tariffs may still be higher than pre-2025 levels, so a full rollback often won't match current inputs. Before those conversations happen, pull historical duty-related costs from your broker and your internal systems, whether that's a spend management provider like Ramp or your ERP, so you're working from clean numbers rather than estimates.

What happens when Section 122 expires?

Section 122 actions are time-limited to 150 days, so the replacement tariffs may end around July 24, 2026 unless renewed or replaced by another authority. If they lapse, tariff rates on affected goods would move closer to pre-IEEPA levels, though Section 301 and Section 232 tariffs would still apply. It's worth modeling at least two cases: Section 122 ends on schedule, or it gets extended.