Currently the process has not been clearly defined. However, we believe the IEEPA tariff refund process will likely allow eligible importers to request a refund of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). This process will be defined by federal agencies upon receipt of direction from the CIT (Court of International Trade).

The IEEPA refunds do not allow for any refunds on any other programs. For example, Section 301 duties are still in full effect.

Eligibility typically includes importers or companies who paid tariffs on goods subject to IEEPA measures and who can demonstrate they meet the refund criteria outlined by the relevant government authority.

JAS can assist in calculating the estimated refund and the related timelines associated with entries.

Absolutely. JAS can assist with filing any refund requests as long as JAS has a power of attorney on file for the importer. JAS will need details such as entry packages (7501, commercial invoices etc.) and ACE data.

JAS can assist to identify entries/and entry lines that are eligible for the potential refunds. Additionally, JAS can file the requests once the final process has been confirmed.

Applicants should prepare invoices, customs entry forms, ACE reports, etc. Note that if JAS filed the entries, most of these documents we will already have.

Currently, it is unclear when refund requests can commence. The Court of International Trade is deliberating to determine answers regarding the process and details related to it.

If refunds are approved, all refunds will be delivered to clients through the ACE ACH refund process. If importers are not set up for ACE ACH refund, they will need to get set up prior to commencement of any refund requests. For FIORs (Foreign Importers of Record), JAS will directly set up the refund process with CBP on behalf of foreign importers. In these cases, the refunds will be sent to JAS via ACH refund and the refunds will then be disbursed to the origin JAS office to deliver the refund to the FIOR.

It is not clear how long it will take to receive refunds at this time. There is a large amount of refunds to process which will result in processing time for CBP to release refunds.

Accelerated liquidation is an option for post summary corrections which CBP “may” liquidate an entry within 60-90 days after the request is made. Note that CBP is not bound by this, however it can be requested during standard PSC processes. However, it is important to note that when accelerated liquidation is selected, the liquidation date is likely going to be earlier than it would have been without accelerated liquidation. Liquidation triggers the protest clock. Protests are allowed within 180 days of liquidation. So, accelerated liquidation will shift the protest clock and make protest filing deadlines sooner.

The best way to calculate your estimated refund is to utilize the ES003 Entry Summary Line Tariff Details report in the ACE portal. Use the date range from January 2025 through March 2026. Then identify all HTS codes which are IEEPA codes and sum the amount of duty paid associated with each of those lines.