U.S. Customs and Border Protection (CBP) has begun accepting refund requests for the $166 billon in tariffs collected under the International Emergency Economic Powers Act following the U.S. Supreme Court’s February 2026 ruling. Business owners and executive teams should assess eligibility, quantify exposure, and prepare to act.
For private company leaders, this is not just a trade issue. It can affect liquidity, forecasting, pricing, and financial reporting.
Background
- In February 2026, the Supreme Court struck down broad tariffs imposed under IEEPA.
- For affected businesses, this may create an opportunity to recover a share of the $166 billion in IEEPA tariffs collected, along with interest.
- CBP has now opened a process for eligible importers to request refunds.
Six Steps for Private Companies to Asses Eligibility and File for Refunds Now
- Confirm eligibility: Determine whether your company was the importer of record and directly paid the tariffs. That is generally the starting point for filing through the Automated Commercial Environment Secure Data Portal (ACE Portal).
- Estimate the opportunity: Quantify potentially refundable tariffs and interest so leadership can assess the possible impact on cash flow and planning.
- Get your documentation in order: Gather customs entry records, broker support, and internal documentation needed to support a claim.
- Prepare to file: CBP has launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) within the ACE Portal. Businesses should confirm portal access, banking information, and filing readiness, and review CBP’s CAPE Declarations Quick Reference Guide.
- Evaluate the broader impact: Any refund may affect financial reporting, taxable income, and forecasts, especially if the amount is material.
- Monitor updates: As the new process rolls out, timing and administration may continue to evolve. Track developments on CBP’s IEEPA Duty Refunds page.
Aldrich Insights
- For private company leaders, the tariff refund process is a chance to recover cash, clarify exposure, and prepare for continued trade policy change.
- The administration of the CAPE system remains in flux, and delays or administrative complications may occur as the process continues to evolve.
