Tax Insight

IEEPA refunds—impact across industries

Insight
5 minute read
April 07, 2026

What happened?

The US Supreme Court ruled on February 20 that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) are not authorized, effectively invalidating those duties. The US Court of International Trade (CIT) subsequently ordered US Customs and Border Protection (CBP) to liquidate unliquidated entries and reliquidate certain non-final entries without IEEPA tariffs, establishing a pathway for potential refunds. Later, on March 27, the CIT amended its prior order to clarify that relief from IEEPA duties also extends to those where liquidation is final, by directing CBP to reliquidate them without IEEPA tariffs.

CBP has proposed developing new functionality within the Automated Customs Environment (ACE), referred to as the Consolidated Administration and Processing of Entries (CAPE), to support an automated, importer-based refund process (that will include interest). In a March 6 declaration to the CIT, CBP indicated that this functionality could be implemented within approximately 45 days (i.e., approximately mid-April). In light of this proposal, the CIT has paused its order requiring immediate refunds, while CBP provides ongoing updates on implementation.

Why is it relevant?

These developments create a significant refund opportunity, estimated at approximately $170 billion, impacting industries, including automotive; industrial products and manufacturing; consumer products; pharmaceutical and medical device; technology, media, and telecommunications (TMT); and energy and utilities. Key considerations remain around the scope of eligible entries, timing and mechanics of refunds, and the operational readiness required to support recovery.

Actions to consider

Companies should begin quantifying potential refunds for IEEPA tariffs and assessing which entries may be eligible for refund based on liquidation status. In parallel, businesses may want to evaluate data availability, align internal stakeholders across tax, trade, and finance, and monitor ongoing legal and administrative developments that could affect the timing and realization of refunds. As highlighted by the industry analysis above, companies also should consider how sector-specific factors such as supply chain complexity, pricing dynamics, and contractual arrangements could influence both the timing and ultimate economic benefit of these refunds.

For more details on industry impacts, read the full Tax Insight linked below.