U.S. Chamber of Commerce
April 6, 2026
The U.S. Supreme Court’s recent decision striking down the tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has opened the door for many U.S. small businesses and importers to seek refunds. However, determining whether your business qualifies—and understanding what steps to take next—can be challenging.
As the refund process is constructed, this guide provides information to help businesses identify whether they paid IEEPA based tariffs, understand what types of duties may be eligible for refunds, and prepare for the emerging refund process.
The Latest: Customs and Border Protection (CBP) has started to release details for a refund process. This agency—which collects all U.S. tariffs and will be responsible for refunding all the IEEPA tariffs collected—expects to launch the system on or around April 20, 2026. Refunds are only available for tariffs applied under IEEPA.
The tariff refund system will distribute refunds to importers through a CBP online, automated system. Importers can take practical steps now to be ready if refunds become available.
4 Things Importers Can Do Now to Prepare for Potential Tariff Refunds
1. Update Importer Record Info
Make sure your CBP importer record (Form 5106) for your company is up-to-date and includes an email address that is not your broker’s email (required for authentication).
Note: Licensed custom brokers have access to the ACE Secure Data Portal and can update Form 5106.
2. Create an ACE Portal Account
Create an account in CBP’s Automated Commercial Environment Secure Data Portal (ACE Portal). This will enable your company to run reports and download entry data to show IEEPA tariff payments for which your company may seek refunds.
Note: Some importers have reported new ACE account setup takes 3-4 weeks.
3. Enroll in ACH Refund
Sign up for Automated Clearinghouse (ACH) Refund. CBP requires ACH enrollment to receive duty refunds electronically. After enrolling for ACH refunds, any refund you receive will automatically be deposited directly into your bank account. Companies may wish to consult with their customs broker or trade counsel.
4. Identify Exceptions
Determine whether all of your IEEPA entries will be covered in the system’s initial rollout, or whether you have entries that are within the two exceptions identified below. If you have entries that fall within the two exceptions, you should consult with your customs broker and lawyer to evaluate whether further action is needed to preserve your right to a refund.