Tariff Refunds: Do You Qualify?

Over the past several years, tariffs have increased costs for many U.S. businesses, especially in manufacturing, distribution, construction, and oil and gas. Some companies managed these costs as part of daily operations, while others faced tighter margins, pricing challenges, and changes to sourcing and supply chains, often without a clear way to recover those expenses.

Recent changes may allow some businesses to recover these costs. Some tariffs under the International Emergency Economic Powers Act (IEEPA) were found invalid, and the federal government has opened a refund portal for eligible businesses to claim back duties they paid.

Since the portal opened on April 20, 2026, this area is still developing and comes with both opportunities and uncertainties. As guidance changes, knowing if your business qualifies, what documentation may be required, and how the process works can help you understand the potential impact.

Who Qualifies for a Tariff Refund?

Eligibility largely depends on whether an organization paid the tariffs in question directly.

Often, businesses qualify if they were the importer of record and can show they paid IEEPA-related duties. This is important because many companies paid higher prices from suppliers but were not the ones who actually paid the duties.

Organizations that may qualify typically:

• Were listed as the importer of record on customs filings
• Can document tariff payments tied to IEEPA-related measures
• Maintain sufficient records to support the claim

Companies that only faced higher costs from vendors or supply chains are usually less likely to qualify. Since supply chains can be complex, determining whether you qualify may require a closer look at contracts, customs filings, and how costs were passed along.

What Documentation Should You Gather?

Getting a claim ready is often the most time-consuming part of the refund process. To support a claim, you may need to gather import and payment records that clearly link your refund request to the duties being challenged.

Relevant documentation may include:

• Entry summaries, such as CBP Form 7501
• Proof of tariff payments, including amounts and dates paid
• Importer of record information
• Shipment, invoice, and transaction records
• Internal records showing how the duties were recorded or allocated

Often, this information is spread across different systems, customs brokers, or third-party vendors, making it harder than expected to put together a complete and consistent claim. A successful claim will likely depend on establishing a clear connection between the importing entity, the goods involved, the tariffs paid, and the refund being requested. Incomplete or inconsistent documentation could make the review process more difficult or increase the likelihood of delays.

How to Submit a Refund Request

Refund requests must be submitted through the U.S. Customs and Border Protection portal.

You can access the portal here:
https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds

The process may seem simple, but many organizations are evaluating eligibility and gathering documentation in advance. A strong claim relies on having complete and consistent records. Missing information or unclear payment proof can delay the review or make it more difficult.

When Should Businesses Expect a Refund?

Due to the portal having opened only recently, processing timelines remain uncertain. Current U.S. Customs and Border Protection guidance indicates that approved claims may generally be processed within approximately 60 to 90 days after approval, though actual timing will likely vary based on claim volume, complexity, and the completeness of the supporting documentation provided.

The review process could still take longer for more complex claims or requests requiring additional support. In the meantime, many businesses are using this period to estimate potential refunds, organize documentation, and prepare for possible follow-up questions or additional guidance as the process continues to evolve.

What This Means for Your Business

For businesses that paid tariffs directly, this is a real chance to recover cash, improve liquidity, and review past cost assumptions. Refunds may also affect financial reporting or help you understand how tariff costs were handled over time.

However, the process is not automatic. It often requires a careful review of your import history, supporting documentation, and eligibility. For businesses with complex supply chains or significant import activity, this review may also highlight bigger questions about sourcing, costs, and compliance.

Position Your Claim Before Guidance Changes

Many businesses are beginning to review their records, evaluate potential eligibility, and identify any documentation gaps that could affect the strength or timing of a claim. A proactive approach can help businesses respond to new guidance as it becomes available and reduce the risk of missed refund opportunities.

Contact your CRI advisor to evaluate your eligibility, prepare supporting documentation, and navigate the tariff refund portal with confidence. Acting quickly and providing strong support for your claim can help your business recover funds that might otherwise go unclaimed and improve your compliance.