IEEPA Tariff Refund Guide

The Supreme Court ruled IEEPA tariffs unconstitutional on February 20, 2026, unlocking $166 billion in refunds for over 330,000 importers. Here is how to claim yours.

Understanding the SCOTUS IEEPA Decision

The Supreme Court's February 20, 2026 ruling in National Foreign Trade Council v. United States was a landmark decision on the separation of powers. The Court held 6-3 that IEEPA, which was designed to give the President authority over financial sanctions and asset freezes during national emergencies, does not extend to imposing tariffs on imported goods. Chief Justice Roberts wrote that the power to lay tariffs is explicitly granted to Congress by the Constitution and cannot be delegated through emergency economic legislation. The ruling invalidated all tariffs that were imposed solely under IEEPA authority.

Who Qualifies for a Refund

Any importer who paid duties on goods where the tariff was imposed under IEEPA authority qualifies for a refund. This includes tariffs on goods from specific countries that were targeted through IEEPA executive orders rather than through Section 301, Section 232, or other traditional trade authorities. Importantly, tariffs imposed under other legal authorities remain in effect. You need to review your entry summaries to determine which of your duties were assessed under IEEPA versus other tariff provisions.

Steps to File Your Refund Claim

First, gather all entry summaries from the period IEEPA tariffs were in effect. Second, identify which entries included duties assessed under IEEPA authority by checking the tariff provision codes. Third, calculate the total refund amount for each entry. Fourth, file amended entry summaries through the ACE portal or your customs broker. Fifth, track your claim status through CBP's refund processing system. MarginHub can help you identify qualifying entries and calculate your total refund amount.

Frequently Asked Questions

What was the SCOTUS ruling on IEEPA tariffs?

On February 20, 2026, the Supreme Court ruled that the use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs exceeded presidential authority. The Court held that tariff power belongs to Congress under the Constitution, making all tariffs imposed under IEEPA authority invalid and refundable.

How much is the total IEEPA refund pool?

The total refund pool is approximately $166 billion, covering all duties collected under IEEPA authority from the date the tariffs were first imposed through the date of the ruling. Over 330,000 importers are estimated to be eligible for refunds.

How do I file for an IEEPA tariff refund?

Refund claims are filed through US Customs and Border Protection using Form 7501 amendments. You will need your original entry summaries, proof of duty payment, and documentation showing the tariffs paid were imposed under IEEPA authority. Claims can be filed electronically through the ACE portal or through a licensed customs broker.

What is the deadline to file for an IEEPA refund?

CBP has established a 180-day claims window from the date of the ruling, giving importers until August 19, 2026 to file refund claims. Claims filed after this deadline may be denied, so importers should begin gathering documentation immediately.

Do I need a customs broker to file a refund claim?

While not legally required, a customs broker or trade attorney is strongly recommended for claims over $10,000. The documentation requirements are specific and errors can delay or disqualify your claim. Many brokers are offering contingency-based services for IEEPA refund claims.

Calculate Your IEEPA Refund

Upload your import history and we will identify which entries qualify for IEEPA refunds and calculate your total claim amount.

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