Following the February 2026 Supreme Court decision that struck down tariffs imposed under the International Emergency Economic Powers Act (IEEPA), the federal government has begun issuing refunds for duties collected since 2025. The scale is significant – estimated at more than $150 billion – but for most companies, the practical impact will take time to materialize.
Refunds are going to the importer of record, meaning the entity that paid the tariff at the border. In many cases, that is the importer or distributor – not the end customer. Whether those funds move through the supply chain will depend on individual business arrangements, and there is no uniform requirement that they do. However, companies should be aware that contractual obligations and evolving case law could influence how refunds are ultimately treated.
The process is underway but far from simple. U.S. Customs and Border Protection launched a claims system on April 20 that requires companies to file for refunds and submit detailed entry data. Many are relying on customs brokers to manage the process. Claims are being handled in phases, starting with the most recent entries.
Even under optimistic timelines, this will not provide quick relief. Guidance suggests refunds could begin arriving 60 to 90 days after claims are accepted, but the scale of the effort, data challenges, and administrative burden point to a longer runway. The inclusion of interest will help offset some costs, particularly for companies with significant exposure. As with the principal, however, any interest payments will go to the importer of record, and whether they move through the supply chain will depend on individual commercial arrangements.
At the same time, companies are running into real friction – data gaps, system access issues, and the complexity of reconciling past imports. Questions also remain around tax treatment and how refunds will flow through financials.
Most importantly, these refunds apply only to IEEPA tariffs. Other tariffs remain firmly in place, including Section 232 duties on steel and aluminum, as well as the new Section 122 global tariff. That leaves companies in a difficult position: recovering past costs while continuing to face new ones.
Recent statements from administration officials reinforce this direction. Treasury Secretary Scott Bessent noted that while the Supreme Court decision was a setback, ongoing Section 301 investigations could lead to tariffs returning to previous levels as early as mid-year.
This is not relief – it’s a delayed correction. Companies will recover some past costs, but they are still operating under new tariffs, higher prices, and continued policy uncertainty with no clear long-term direction.
For more information, watch AMT – The Association For Manufacturing Technology’s recent webinar “Navigating the Ever-Evolving Trade Landscape,” presented by K&L Gates.
