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IEEPA Tariffs

What They Are, the Key Court Rulings, and How IEEPA Refunds May Work

Did Your Business Pay IEEPA Tariffs?

On February 20, 2026, the U.S. Supreme Court held that IEEPA does not authorize the President to impose tariffs. That decision changed the legal landscape for businesses that paid IEEPA tariffs and created a major opportunity for many importers to evaluate potential refunds.

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If your company paid duties under the IEEPA tariff framework, now is the time to review your import history, determine whether your entries were affected, and understand what refund options may be available through the current CBP process. CBP says Phase 1 refund requests through CAPE begin April 20, 2026.

No upfront fees. You only pay if a refund is recovered.

What Are IEEPA Tariffs?

IEEPA tariffs are tariffs imposed under executive orders that relied on the International Emergency Economic Powers Act, or IEEPA, as the claimed source of authority. In the litigation over IEEPA tariffs, courts rejected the government’s argument that IEEPA’s power to “regulate” importation included the power to impose broad tariffs. The Supreme Court ultimately held that it did not.

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For businesses searching “IEEPA tariffs,” the core issue is no longer just what they were. It is whether duties paid under that framework may now be recoverable.

When Were IEEPA Tariffs Imposed?

The main IEEPA tariff actions challenged in court began on February 1, 2025. According to the Federal Circuit, those measures included 25% duties on products of Canada, 25% duties on products of Mexico, and 10% duties on products of China.

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A second major wave followed on April 2, 2025, when reciprocal tariffs were imposed, including a baseline 10% ad valorem duty on imports from nearly every country. The China-specific reciprocal rate later rose sharply in April 2025 before later modifications and pauses.

Key Court Rulings on IEEPA Tariffs

August 29, 2025

Federal Circuit Affirms That IEEPA Did Not Authorize the Tariffs

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In V.O.S. Selections, Inc. v. Trump, the U.S. Court of Appeals for the Federal Circuit ruled that IEEPA did not authorize the challenged tariffs. The court described the tariffs as sweeping in scope and rejected the claimed statutory basis for them.

February 20, 2026

Supreme Court Decision​

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In Learning Resources, Inc. v. Trump, the U.S. Supreme Court held that “IEEPA does not authorize the President to impose tariffs.” That is the central ruling driving today’s interest in IEEPA tariff refunds.

March 2026 & After

Refund Mechanics Begin Taking Shape

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After the Supreme Court ruling, attention shifted from whether the tariffs were lawful to how refunds would be handled. Skadden reported that the U.S. Court of International Trade, through Atmus Filtration, Inc. v. United States, ordered CBP to refund approximately $165 billion in unlawfully collected IEEPA duties. Reuters separately reported that CBP was building a system to refund about $166 billion in tariff collections deemed illegal by the Supreme Court.

Why the IEEPA Tariff Cases Matter

The IEEPA tariff decisions matter because they limit how far emergency-powers statutes can be stretched to support broad tariff policy. The Supreme Court framed the case as one involving Congress’s constitutional power over duties and rejected the idea that IEEPA’s general reference to regulating importation silently transferred that power to the President for tariffs of broad scope, amount, and duration.

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They also matter because real money is involved. Importers that paid duties under the invalidated IEEPA framework may have significant sums tied up in entries affected by those executive orders. The size of the potential refund pool has been measured in the hundreds of billions of dollars across major public estimates and agency reporting.

IEEPA Tariffs & Refund Opportunities

If your business paid IEEPA tariffs, a review may help determine whether you have a viable refund opportunity. The most important questions usually include:

  • whether your entries were subject to the challenged IEEPA tariff measures

  • whether supporting import records are available

  • whether the claim fits within the current CBP filing process

  • whether the amount at stake justifies immediate action

 

Those are practical intake questions based on the current refund framework described by CBP.

Industries Commonly Affected by IEEPA Tariffs

Because the challenged IEEPA tariffs affected imports from Canada, Mexico, China, and later nearly every country, the impact was broad. Businesses with global supply chains, imported finished goods, components, or manufacturing inputs were especially likely to be affected. That follows directly from the scope of the tariff actions described in the Federal Circuit’s opinion.

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.

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1. Schedule A Call

Choose a time to speak directly with our team. 

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2. Submit Your Information

Share a few key details about your business to begin your eligibility review.

Tariff Refund Eligibility

3. Review Eligibility

We walk through your situation, determine whether you qualify for a refund, and lay out next steps.

Find out whether your business may qualify for an IEEPA Tariff Refund.

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