Tariff Recovery
If your business imported goods into the U.S. and paid IEEPA tariff duties, you may be entitled to recover those funds. BHL helps businesses understand whether they may qualify and what the recovery process could involve.
A significant refund opportunity for U.S. 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
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, or indirectly through carriers or intermediaries, such as FedEx, UPS, and DHL. There is a wide range of industries that may be impacted, including:
There is a wide range of industries that may be impacted, including:
- Consumer goods and retail businesses
- Electronics and technology hardware importers
- Industrial and manufacturing businesses
- Automotive parts and components companies
- Textile, materials, and packaging businesses
- Food, beverage, and agriculture importers
- Wholesale and distribution businesses
- Health, medical, and pharma-related importers
The strongest-fit businesses are typically those with meaningful import volume during the IEEPA tariff period (February 4, 2025 through February 24, 2026) and potential refund exposure that meets a practical threshold for pursuing recovery. This includes both direct importers (Importers of Record), who paid duties to U.S. Customs, and businesses that may have absorbed tariff-related costs indirectly through carriers, suppliers, or intermediaries—such as FedEx, DHL, and UPS, as well as freight forwarders, customs brokers, or overseas suppliers passing through tariff-related charges.
While direct importer claims are generally more straightforward, certain secondary claims may also be viable, though the legal framework for those continues to evolve.
Why this process can be more involved 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
Support across the tariff recovery 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
Why act now
Import entries move through liquidation on a rolling basis, and once certain deadlines pass, recovery rights on those entries may be lost. Importers who prepare in advance may be better positioned once the refund mechanism is fully operational.
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
Find out if your business may be eligible for tariff recovery
If your business imported goods into the U.S. during the IEEPA tariff period, it may be worth taking a closer look at whether a refund opportunity exists.
Biz Head Law can help you review your situation, identify whether there may be a viable path forward, and walk you through what the recovery process could involve.
An initial consultation is straightforward and designed to help you understand whether this is something worth pursuing—without requiring you to have all of your data organized upfront.
Given the timing considerations involved, many businesses are choosing to review their position sooner rather than later.
No obligation. We’ll help you understand whether this opportunity is worth exploring for your business.
Frequently Asked Questions
What if we’re not sure whether we paid IEEPA tariffs?
That’s very common. Many businesses don’t have clear visibility into tariff costs at a detailed level. A review of import activity, broker data, invoices, or shipping records can help determine whether your business may have been affected.
What if our data is spread across multiple brokers or systems?
This is a common issue. Many importers have records across different brokers, ports, or internal systems. Identifying and reconciling that data is often part of the review process.
What if we used carriers like FedEx, UPS, or DHL instead of importing directly?
Even if another party handled the import, your business may still have absorbed tariff-related costs. These situations can be more fact-specific and may require additional analysis to determine whether recovery may be available.
Do we need to know our exact tariff amount before reaching out?
No. Many businesses begin the process without knowing their exact exposure. An initial review can help determine whether there may be a meaningful opportunity and what information would be needed next.
Are all tariffs eligible for refund?
No. Not all tariff programs are part of this opportunity. A review is typically needed to determine which charges, if any, may be eligible for recovery.
What role does the ACE portal play?
The Automated Commercial Environment (ACE) is the system used to access import and customs data. It is often an important part of identifying entries, confirming duty payments, and preparing for potential refund claims.
What if we made changes during the tariff period (suppliers, classifications, pricing)?
Changes to sourcing, classification, or documentation during the tariff period are not uncommon. However, they can introduce additional considerations that may need to be reviewed before pursuing a claim.
What happens after we get in touch?
The next step is typically an initial consultation to review your business’s import activity, discuss whether there may be a viable path forward, and outline what the process could involve.
Is there any downside to having our situation reviewed?
An initial review can help clarify whether the opportunity is meaningful for your business before taking further steps, without requiring a commitment to proceed.
Legal Disclaimer
The information provided on this website is for general informational purposes only and does not constitute legal advice. Viewing this website, submitting an inquiry, or communicating with Biz Head Law LLC or its affiliated attorneys does not create an attorney-client relationship.
An attorney-client relationship is formed only upon the execution of a written engagement with Biz Head Law LLC. Any descriptions of potential recovery, outcomes, or results are estimates based on general information and are not guarantees of future performance. Every matter is fact-specific and subject to applicable law, regulations, and procedural requirements. This website may reference legal services provided in collaboration with co-counsel or affiliated law firms. Certain matters may be referred to or handled jointly with other attorneys licensed in jurisdictions where services are required. Not all attorneys referenced are licensed in every jurisdiction.
Biz Head Law LLC is an Illinois law firm. Attorney Kevin Chern is licensed in the State of Illinois and is responsible for the content of this website. He is not licensed to practice law in all jurisdictions. Legal services will be provided by attorneys licensed in the appropriate jurisdiction for each matter. Nothing on this website should be interpreted as a guarantee that any specific result will be obtained. Legal decisions should be made only after consultation with qualified legal counsel based on the specific facts and circumstances of your situation.
To the extent required by applicable rules of professional conduct: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers.