The Complete Guide to IEEPA Tariff Refunds in 2026
The U.S. Supreme Court ruled that IEEPA tariffs are unlawful, but refunds are not automatic. This guide explains your recovery pathways and deadlines.
After the Supreme Court's ruling invalidating IEEPA tariff authority, importers hold hundreds of millions of dollars in recoverable duty payments. The ruling did not create an automatic refund. Recovery depends on which pathway matches each entry's status.
The three pathways
- Post-Summary Correction (PSC) — for entries still unliquidated. Window: up to 300 days after entry. Lowest fee, fastest processing.
- CBP Form 19 Protest — for entries that have liquidated. Window: 180 days from liquidation. Moderate fee, higher administrative load.
- Court of International Trade (CIT) action — for denied protests, expired windows, or complex disputes. Handled by admitted trade counsel.
Decision framework
Start with an ACE entry history pull. Segment entries by status (unliquidated / liquidated / denied). Run the PSC clock against the earliest entries first — they are closest to expiration. Protests follow. CIT actions are triaged last because they have the longest effective timeline but the highest procedural threshold.
What not to do
- Do not assume your customs broker is filing refunds. Brokers file entries. Refund recovery is separate work.
- Do not wait for the CAPE portal. It is not a statutory pathway and it does not stop deadlines from running.
- Do not sell receivables to duty-trader funds without comparing what a contingency recovery would net.
The math on IEEPA refunds is simple: file within the windows and recover most of the duty. Miss the windows and recover little or nothing.
TariffAuditLabs is a tariff recovery service, not a law firm. We prepare Post Summary Corrections and CBP protests and file them through your licensed customs broker. For Court of International Trade matters, we refer clients to independent CIT-admitted trade counsel; those engagements are contracted and priced directly with counsel and we do not share legal fees. This article is general information about IEEPA refund recovery and is not legal advice for any specific importer. Deadlines vary by entry; confirm your position with qualified counsel before relying on anything here.
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