New York State Tariff Relief Program vs. Federal Tariff Refund: What Importers and Farmers Must Know

By Jeb Singer, Managing Partner, Singer Law Group | Singer Tariff Recovery

A New York State tariff relief program and the federal tariff refund process are not the same thing.

That distinction matters for U.S. businesses trying to determine whether they can recover money connected to tariffs.

For importers, the federal process focuses on customs duties actually paid on imported goods. After the Supreme Court’s February 20, 2026 ruling on IEEPA tariff authority, qualifying U.S. importers need to identify the affected entries, determine where those entries stand in the customs process, and follow the appropriate recovery path.

A state relief program does not replace that process.

If your business directly paid IEEPA duties as the Importer of Record, the question is not simply whether tariff relief exists. The real question is whether your customs entries qualify for an IEEPA tariff refund, where those entries stand, and what filing requirements or deadlines apply.

That starts with the records.

What Is the New York State Tariff Relief Program?

State tariff relief and federal customs duty recovery address different types of financial harm.

A state program designed to provide economic relief to businesses or agricultural producers affected by tariff policy should not be confused with the federal customs process used by importers seeking the return of duties paid to U.S. Customs and Border Protection.

For an importer, that distinction is critical.

If your company paid customs duties on imported merchandise, you need to determine what duties were actually paid, which entity appears as the Importer of Record, whether the entries contain qualifying IEEPA duties, and where each entry stands in the customs process.

The fact that another tariff-related relief program exists does not automatically create a customs refund claim.

Your customs records do.

What Is the Federal IEEPA Tariff Refund Process?

The federal tariff refund process addresses qualifying IEEPA duties paid by U.S. importers.

IEEPA tariffs added import duties to existing tariff obligations beginning in 2025. On

February 20, 2026, the U.S. Supreme Court ruled that IEEPA did not authorize the President to impose the tariffs at issue.

That ruling created an opportunity for qualifying U.S. importers to recover duties they previously paid.

But the refund process is not automatic.

An importer still needs to determine which entries contain the IEEPA duties under review,

confirm the Importer of Record, review liquidation and reconciliation status, identify prior administrative activity, and determine which recovery procedure applies.

For a broader explanation of the decision and what it means for businesses that paid these duties, Singer Tariff Recovery’s IEEPA Supreme Court tariff ruling analysis explains the framework.

CAPE, or Consolidated Administration and Processing of Entries, is one part of that recovery process.

Some entries can move through CAPE. Other entries require additional review because of liquidation, reconciliation, prior administrative action, or another customs issue.

That is why the first question should not be:

How much did our company pay in tariffs?

It should be:

Which entries are affected, and where does each one stand?

Singer Tariff Recovery’s CBP CAPE importer qualification guidance explains why the Importer of Record, ACE access, liquidation status, reconciliation status, and entry-level records need review before a company decides what to file.

Understanding the Difference Between State Relief and Federal Tariff Recovery

The most important distinction is what each process is designed to address.

A state economic relief program does not determine whether CBP owes an importer a refund.

Federal tariff recovery focuses on customs entries and duties paid.

For an importer, that means the relevant records include:

• Entry numbers

• Importer of Record information

• IEEPA duties paid

• Entry type

• Reconciliation status

• Liquidation status

• Liquidation date

• Prior administrative activity

• Potential protest rights

• Applicable recovery process

A company can be affected economically by tariffs without having a federal customs refund claim.

Likewise, a U.S. importer that directly paid qualifying IEEPA duties can have a potential federal recovery even though it does not participate in a state tariff relief program.

These are different questions.

How Do These Two Types of Tariff Relief Compare?

The distinction becomes clearer when you look at what the business is actually trying to recover.

Who It Serves

• State Tariff Relief: Businesses or producers that satisfy the requirements of the particular state program

• Federal IEEPA Tariff Recovery: U.S. importers reviewing qualifying IEEPA duties paid on customs entries

What It Addresses

• State Tariff Relief: Economic losses or other harm addressed by the particular state program

• Federal IEEPA Tariff Recovery: Qualifying customs duties paid on imported goods

What Records Matter

• State Tariff Relief: The records required by the particular state program

• Federal IEEPA Tariff Recovery: ACE data, customs entries, Importer of Record information, duty records, reconciliation information, liquidation status, and prior administrative activity

Who Handles the Federal Customs Process

• State Tariff Relief: Separate from CBP’s customs refund procedures

• Federal IEEPA Tariff Recovery: U.S. Customs and Border Protection, with federal court involvement when legal issues require judicial review

Geographic Scope

• State Tariff Relief: Limited by the requirements of the particular state program

• Federal IEEPA Tariff Recovery: Applies to qualifying U.S. importers based on their customs entries and duties.

What Determines the Recovery Path

• State Tariff Relief: The rules of the applicable state program

• Federal IEEPA Tariff Recovery: Entry status, Importer of Record information, duties paid, liquidation, reconciliation, prior filings, and other customs factors

A New York business can therefore have more than one tariff-related issue to evaluate.

The key is not to treat different programs as interchangeable.

For customs duty recovery, start with the federal customs records.

What Are the Most Common Misconceptions About These Programs?

Confusion around tariff relief can cause businesses to focus on the wrong process while deadlines continue to run on their customs entries.

Misconception 1: “A state tariff relief program will recover the customs duties my business paid.”

A state economic relief program is not a substitute for the federal customs recovery process.

If your business paid IEEPA duties as an Importer of Record, the recovery analysis begins with the customs entries.

Identify what was paid.

Confirm the Importer of Record.

Determine which entries contain the duties under review.

Then determine where those entries stand.

Misconception 2: “Every importer automatically receives a refund after the

Supreme Court ruling.”

The Supreme Court ruling created a significant recovery opportunity, but importers should

not treat the decision as an automatic refund.

The company still needs to identify affected entries and determine the appropriate administrative or legal path.

For some entries, CAPE can be part of the recovery process.

Other entries require a different analysis based on liquidation, reconciliation, prior filings, or other customs issues.

Misconception 3: “If we know how much we paid in tariffs, we know how much we can recover.”

A company-wide tariff expense is a starting point. It is not the recovery analysis.

An accounting department could know the business paid millions of dollars in tariffs without knowing which entries contain qualifying IEEPA duties, which entities appear as the Importer of Record, whether the entries have liquidated, or whether reconciliation applies.

The recovery needs to be tied back to the entries.

Misconception 4: “All customs entries follow the same refund process.”

They do not.

An importer can have hundreds or thousands of entries that look similar on an accounting report but sit in very different procedural positions.

Some entries can fit within CAPE.

Others have already been liquidated.

Some involve reconciliation.

Others have prior administrative activity that needs to be considered.

That is why an ACE data and customs entry review should come before the company decides what to file.

What Should New York Businesses and U.S. Importers Do Now?

Businesses evaluating any state-level tariff relief should first understand what that particular program is designed to address.

U.S. importers seeking federal tariff recovery have a different job.

They need to organize the customs records and determine what each entry requires.

For Businesses Evaluating State Tariff Relief

Determine exactly what the program covers before treating it as a customs recovery option.

Ask:

• What financial harm is the program designed to address?

• Who qualifies?

• What documentation is required?

• Does the program actually refund customs duties?

• Is it separate from the federal CBP process?

If the goal is to recover IEEPA duties paid to CBP, turn to the customs entries.

For U.S. Importers Seeking Federal Tariff Refunds

Start with the records.

Pull the customs entry history.

Identify the entries containing IEEPA duties.

Confirm the Importer of Record.

Review reconciliation status.

Check whether each entry has been liquidated.

If it has, identify the liquidation date.

Determine whether any protest, reconciliation, CAPE submission, or other administrative action has already occurred.

Then separate the entries according to the recovery issue that needs attention.

This is especially important for businesses with large entry populations.

One entry can be positioned differently from another even when both involve the same importer, product line, or tariff period.

Liquidation dates deserve particular attention because you generally must file a customs protest within 180 days of liquidation. Singer Tariff Recovery’s customs protest and CAPE strategy explains why CAPE preparation and liquidation review should happen together, not one after the other.

Do not assume that filing through one administrative process automatically protects rights tied to another.

Know what was filed.

Know which entries were included.

Know which deadlines still need attention.

How Does Singer Tariff Recovery Help U.S. Importers

Navigate Federal Tariff Refunds?

Singer Tariff Recovery works with U.S. importers to identify, organize, and pursue potential customs duty recovery opportunities.

The process begins with the entries.

The team reviews customs records to identify affected entries, Importer of Record information, IEEPA duties under review, reconciliation status, liquidation information, and

prior administrative activity.

From there, entries can be organized according to the recovery path that fits their status.

That can include CAPE submissions, customs protests, additional administrative review, or Court of International Trade analysis when legal issues require it.

For importers with large customs portfolios, this records-first approach is especially

important.

A business can have hundreds or thousands of entries spread across different brokers, entities, product lines, ports, and liquidation dates.

Treating all of those entries as one refund claim can hide important differences.

Singer Tariff Recovery identifies those differences before deciding what to file.

When an entry raises issues that require judicial review, Singer Law Group can also evaluate tariff refund litigation at the Court of International Trade.

The goal is straightforward.

Understand what the importer paid.

Identify the affected entries.

Determine where each entry stands.

Protect the available recovery paths.

Then build the filing strategy around what the customs records actually show.

Jeb Singer, Managing Partner of Singer Law Group and co-founder of Singer Tariff Recovery, was admitted to practice in New York in 2009 and founded J. Singer Law Group in 2014. His approach to tariff recovery reflects the same records-first strategy used

throughout the practice: identify the affected entries, understand their procedural status, protect applicable deadlines, and determine the appropriate recovery path before filing.

Singer Tariff Recovery serves importers across industries, including furniture, sporting goods, electronics, apparel, industrial components, and other businesses that paid qualifying IEEPA duties.

If your company paid IEEPA tariffs, the first step is determining whether the entries fit the current recovery framework. The IEEPA tariff refund eligibility analysis explains the entry-level questions importers should answer before filing.

Frequently Asked Questions

What is the difference between a New York State tariff relief program and a federal tariff refund?

They address different issues.

A state tariff relief program operates under the requirements established for that particular state program. A federal tariff refund involves customs duties paid on imported merchandise and requires analysis of the importer’s federal customs records.

For a business seeking recovery of IEEPA duties paid to CBP, the relevant analysis starts with the customs entries, Importer of Record, duties paid, liquidation status, reconciliation status, and available federal recovery procedures.

Does state tariff relief automatically qualify my company for a federal IEEPA refund?

No.

Federal IEEPA tariff recovery depends on the importer’s customs records and the status of the affected entries.

Participation in another tariff-related program does not replace that analysis.

Who should review a potential IEEPA tariff refund?

The first question is who appears as the Importer of Record on the affected customs entries.

From there, the company should identify which entries contain the IEEPA duties under review, what amounts were paid, where those entries stand, and which recovery procedure applies.

Are IEEPA tariff refunds automatic?

No.

Importers still need to identify affected entries, review their status, organize supporting records, and use the appropriate administrative or legal recovery process.

What is CAPE?

CAPE stands for Consolidated Administration and Processing of Entries.

It is part of the administrative process used for qualifying IEEPA duty refunds through the ACE Secure Data Portal.

An importer should not assume that every entry containing an IEEPA duty automatically belongs in the same CAPE filing. Entry type, Importer of Record information, reconciliation status, liquidation, prior administrative activity, and other factors can affect what happens next.

Why does the liquidation date matter?

Liquidation can affect the procedures and deadlines available for an entry.

A post-liquidation customs protest generally must be filed within 180 days of liquidation. For importers with large entry populations, that can mean different entries have different deadlines running at the same time.

Review liquidation status early rather than waiting until the rest of the refund analysis is complete.

Does filing a CAPE declaration stop the customs protest deadline?

Importers should not assume that a CAPE filing suspends or replaces a separate deadline

tied to a liquidated entry.

CAPE preparation and liquidation review should happen together so you can identify time-sensitive entries while the broader recovery work continues.

What records should an importer collect before pursuing an IEEPA tariff refund?

Start with the customs records.

That generally includes:

• ACE entry data

• Entry summaries

• Importer of Record information

• Duty payment information

• Liquidation status and dates

• Reconciliation information

• Prior protest or administrative activity

• Commercial invoices and supporting customs documentation

• Records of previous CAPE filings, where applicable

For a company with multiple brokers or business entities, make sure the review captures the full entry history rather than relying on one source.

What if some of our entries have already liquidated?

Separate those entries from the rest of the population and review their liquidation dates, procedural history, protest status, reconciliation information, and other relevant customs

activity.

Do not assume that every liquidated entry follows the same path.

The entry history determines what to evaluate next.

Can Singer Tariff Recovery help determine which recovery path applies?

Yes. Singer Tariff Recovery works with U.S. importers to organize potential tariff recovery opportunities from the underlying customs records.

The process starts by identifying affected entries, confirming Importer of Record information, separating the duties under review, and organizing liquidation, reconciliation, and

administrative status.

From there, the team can determine which entries fit the applicable administrative recovery process and which require additional customs or legal review.

Start With the Entries, Not the Headline

Tariff relief can mean very different things depending on the program involved.

For U.S. importers, the important distinction is whether the business is seeking economic relief through a separate program or trying to recover customs duties it actually paid to CBP.

If the goal is recovering qualifying IEEPA duties, start with the customs records.

Identify the entries.

Confirm the Importer of Record.

Determine what duties were paid.

Check reconciliation and liquidation status.

Identify deadlines.

Review prior administrative activity.

Then determine the recovery path for each group of entries.

Don't assume every entry follows the same process, and don't let a company-wide tariff

number replace an entry-level review.

Singer Tariff Recovery was co-founded by Jeb Singer, Benjamin Weiss, and Pamela Gold to help U.S. importers work through the customs records, filing requirements, and legal issues

involved in tariff recovery.

If your company paid IEEPA tariffs and you want to determine what's recoverable, which entries belong in CAPE, which need additional review, and what deadlines need attention now, schedule a consultation with Singer Tariff Recovery.

Call (917) 905-8280 to discuss your import history and potential tariff recovery.

Start with the entries. Know their status. Protect the available paths. Then build the recovery strategy around what your customs records actually show.