IEEPA Refunds
The Current Situation
The US Supreme Court ruled on February 20th that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) are not authorized, effectively invalidating those duties. Later, on March 27th, the US Court of International Trade (CIT) amended its prior order to clarify that relief from IEEPA duties also extends to those where liquidation is final, by directing US Customs and Border Protection (CBP) to reliquidate them without IEEPA tariffs.
​
CBP has proposed developing new functionality within the Automated Customs Environment (ACE), referred to as the Consolidated Administration and Processing of Entries (CAPE), to support an importer-based refund process.
What does this mean?
These developments create a significant refund opportunity, estimated at ~ $170 billion, impacting a cornucopia of industries, including automotive consumer products; pharmaceutical and medical device; technology, media, and telecommunications (TMT); and energy and utilities, and industrial products and manufacturing.
So what should my company do now?
Companies should begin quantifying potential refunds for IEEPA tariffs and assessing which entries may be eligible for refund based on liquidation status. At the same time, businesses may want to evaluate data availability and align all internal stakeholders. Companies should also consider how sector-specific factors such as supply chain complexity, pricing dynamics, and contractual arrangements could influence both the timing and ultimate economic benefit of these refunds.
Industry breakdown of tariff refunds
Tariff and import data suggest that IEEPA duty collections, and therefore refunds, will affect a wide range of industries. Industries with high import reliance and complex supply chains are expected to capture a substantial share of potential refunds.
To illustrate the scale of potential impact, PwC performed an analysis of the IEEPA refund amounts based on countries of origin.
This analysis takes CBP Trade Statistics as of December 14, 2025, and performs calculations to estimate potential IEEPA impact through February 18, 2026, in Figure 1 below.
Figure 1: Importer jurisdictions and potential tariff refund
These tariffs vary significantly by industry.
​
The following figure outlines potential refunds and considerations for key industries.
Figure 2: Top industries – total potential tariff refund by industry
Industry observations
Industrial Products and Manufacturing: Companies in this sector face tariffs on machinery, equipment, and intermediate goods, typically embedded in the cost of goods sold. Refunds could directly improve margins or earnings. However, decentralized importing structures and multiple entities may require significant data consolidation to support claims, along with consideration of supplier/customer agreements and tariff pass-through provisions. Estimated potential refunds: $39.7 billion.
Consumer Products: Consumer products companies are impacted by tariffs on imported finished goods like apparel, footwear, and retail merchandise, often sourced from a few key regions. The benefit of refunds depends on pricing strategies and whether tariff costs were shared with suppliers or passed on to customers. Companies may also need to consider inventory timing and ownership when evaluating financial impacts. Estimated potential refunds: $23.9 billion.
​
Automotive: The automotive sector is impacted mainly by tariffs on imported components within complex global supply chains, often applied at multiple production stages. Overlap with other trade measures (such as Sections 232 and 301) may complicate the timing and coordination of refunds. Supplier–OEM agreements, cost-sharing, and transfer pricing can also affect how refunds are distributed. Estimated potential IEEPA tariff refunds: $19.9 billion.
Pharmaceutical and Medical Device: This sector is affected by tariffs on imported ingredients, medical devices, and specialized components. Complex supply chains, regulatory requirements, and contractual agreements can make it harder to track duties and determine the financial impact of potential refunds.
Estimated potential refunds of IEEPA tariffs for this sector total approximately $18.1 billion.
Technology, Media, and Telecommunications (TMT): The TMT sector is impacted by tariffs on high-value imports like electronics, semiconductors, and networking equipment. Large import volumes and complex global supply chains increase both refund opportunities and the effort required to claim them. Refunds could significantly improve margins and inventory values, especially when costs were absorbed. The benefit may vary if costs were passed to customers, shared with suppliers, or built into transfer pricing. Estimated potential refunds: $47.6 billion.
Energy and Utilities: This sector is affected by tariffs on imported equipment, infrastructure components, and some raw materials. While the overall impact is smaller than in other sectors, large capital projects with imported inputs could still see meaningful refunds. Contract structures and regulated pricing may affect how benefits are realized. Estimated potential refunds: $11.3 billion.
How to Claim Your Refund
Three simple steps to determine what your business may be owed. You pay nothing unless a refund is recovered. For qualifying claims, advance funding may be available so your business can access funds sooner rather than waiting on the government’s refund process.
1. Schedule A Call
Choose a time to speak directly with our team.
​
2. Submit Your Information
Share a few key details about your business to begin your eligibility review.
3. Review Eligibility
We walk through your situation, determine whether you qualify for a refund, and lay out next steps.