You may be seeing increased attention around tariff refunds following recent legal and regulatory developments. While some organizations have begun receiving refunds, the process is still evolving—and for many businesses, the situation is more nuanced than it may appear.
Here’s a practical, high-level guide to what we’re seeing and what to consider.
Not Every Business Will Be Eligible
Tariff refunds primarily apply to importers of record (IORs)—the entity officially responsible for importing goods into the U.S. and interacting directly with U.S. Customs and Border Protection (CBP).
For many middle-market companies, that is not how imports are structured. If you work through a third-party importer, broker, or logistics provider:
- You may pay tariffs as part of your costs
- But you may not be the importer of record
Only the IOR or a licensed Customs Broker authorized to submit claims on the IOR’s behalf can directly submit claims vis the U.S. Customes and Border Protection’s ACE Secure Data Portal.
What This Means in Practice
If your company is not the importer of record:
- The importer or logistics provider typically receives any refund
- Your ability to benefit depends on your contractual arrangement
- Refunds may be shared, credited, or retained depending on that agreement
Understanding your role in the import process is often the most important first step.
If You Are the Importer of Record
Refunds are currently limited to specific tariff types and timeframes.
What tariffs are eligible?
Refunds apply only to certain tariffs imposed under IEEPA (International Emergency Economic Powers Act) that were later invalidated.
- Other tariffs (such as Section 232 or Section 301) are not included
Which shipments currently qualify?
CBP is processing refunds in phases.
Phase One is limited to:
- Certain unliquidated entries (not yet finalized by CBP)
- Certain entries within ~80 days of liquidation
This is a narrow subset of entries, and additional phases are expected but not yet defined.
What does “liquidated” vs. “unliquidated” mean?
- Unliquidated entry: CBP has received the entry but has not finalized the duties
- Liquidated entry: CBP has completed its review and finalized the entry
Only specific entries in these categories are currently eligible in Phase One.
Timing and Refund Status
Refund processing is not immediate and follows a multi-step process:
- CBP reviews and approves refund requests
- Approved refunds are issued to the importer of record
- Processing timelines are estimated at 60–90 days from filing, though timing can vary.
Because refunds are being processed in phases, some eligible payments may not yet be addressed.
For updates and official guidance, refer to: CBP IEEPA Duty Refunds Page
What About Older or Different Entries?
CBP has not yet released detailed guidance for:
- Entries outside the current 80-day window
- More complex cases or historical filings
These are expected to be handled in future phases, though timing has not been confirmed.
Anders’ Role
Although we are unable to submit claims directly to the CBP ACE Secure Data Portal or act as a third-party refund processor, we can assist clients in the following ways:
- Understand whether this applies to your situation
- Clarify whether you are the importer of record
- Identify the appropriate next step or resource
- Assist in managing any tax or financial statement impact
What to Do Next
If tariff refunds may apply to your business:
- Confirm whether you are the importer of record
- Identify who manages your imports (internal vs. third party)
- Review your agreements with that provider
- Refer to CBP resources for the most current guidance
Final Thought
While tariff refunds are real, they apply to a specific subset of businesses and transactions. For many organizations, the key question is not “how do we file?” but rather:
“Are we even the party eligible to file?”
Understanding that distinction can help avoid unnecessary effort—and point you toward the right next step.