IEEPA Tariff Recovery

If your business imported goods into the U.S. and paid IEEPA tariff duties, you may be entitled to recover those funds. Biz Head Law helps businesses understand whether they may qualify and what the recovery process could involve.

There's a significant refund opportunity for US importers.

Following a February 2026 Supreme Court ruling, IEEPA tariffs were struck down, and the Court of International Trade has directed U.S. Customs and Border Protection to begin processing refunds of all amounts collected under those tariffs, plus interest.

This represents a large-scale recovery opportunity, with more than $166 billion in refunds potentially owed to over 330,000 importers. It is also estimated that as many as a million more businesses may have absorbed tariff-related costs indirectly through carriers like FedEx, UPS, and DHL.

Despite the size of the opportunity, many businesses are not yet positioned to take the steps required to recover what they paid. In fact, a significant majority have not completed basic setup requirements—such as establishing access to the Automated Commercial Environment (ACE), which is often the first step in a broader process required to receive an electronic refund.

Recovering these funds is not automatic.

Businesses may need access to detailed customs data, a clear understanding of their filing position, and a strategy for navigating deadlines, documentation, and compliance considerations throughout the process.

Who may want to explore tariff recovery with Biz Head Law?

This opportunity may be relevant for businesses that imported goods into the U.S. during the IEEPA tariff period and paid duties directly as the Importer of Record.

The strongest-fit businesses are typically those with meaningful import volume during the IEEPA tariff period (February 4, 2025 through February 24, 2026), with potential refund exposure that meets a practical threshold for pursuing recovery, and are direct importers (Importers of Record) who paid duties to U.S. Customs.

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Consumer goods and retail businesses

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Electronics and technology hardware importers

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Industrial and manufacturing businesses

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Automotive parts and components companies

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Textile, materials, and packaging businesses

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Food, beverage, and agriculture importers

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Wholesale and distribution businesses

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Health, medical, and pharma-related importers

The process can be harder than it seems.

Tariff recovery is not just a matter of submitting a simple form. The process can involve customs data review, refund calculations, deadline tracking, audit preparation, compliance analysis, and potentially federal court action.

Businesses may also run into complications such as:

import data spread across multiple customs brokers
uncertainty around liquidation deadlines
sourcing or classification changes made during the tariff period
incomplete ACE setup or refund-readiness
questions about whether a broker alone is handling the full legal and compliance picture

Full support throughout the process.

The recovery process may require support across a number of stages, such as:

ACE portal and ACH setup support
Import entry reconciliation across brokers
Tariff isolation and refund analysis
Refund calculation and interest review
Audit file and documentation preparation
Compliance and risk assessment
Liquidation event and deadline monitoring
Protest management and submission support
Refund filing support
Court-related strategy and representation where needed.

If your business paid any tariffs, review your position today.

If your business may have paid IEEPA tariffs, it may be worth reviewing your position sooner rather than later, especially if

you imported at scale during the relevant period
you used more than one customs broker
your data is fragmented or difficult to reconcile
you changed sourcing, classification, or documentation practices during the tariff period
you are unsure whether your current advisor is handling both the operational and legal side of recovery