On February 20, 2026, the U.S. Supreme Court ruled 6-3 in Learning Resources, Inc. v. Trump that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to impose tariffs. Every IEEPA-based duty collected since 2025 is now legally void. Between $133 billion and $175 billion in overpaid duties are sitting in U.S. Treasury accounts — and importers are entitled to get that money back, plus interest. This guide explains exactly who qualifies, how to file, and what deadlines you cannot afford to miss.

In This Guide

The Ruling That Changed Everything

On February 20, 2026, the United States Supreme Court handed down the most consequential trade decision in modern American history. In a 6-3 ruling in Learning Resources, Inc. v. Trump, the Court held that the International Emergency Economic Powers Act (IEEPA) does not grant the president the authority to impose tariffs on imported goods.

The IEEPA, enacted in 1977, gives the president broad powers to regulate economic transactions during declared national emergencies. Since early 2025, the Trump administration had relied on IEEPA as the legal foundation for sweeping tariffs on imports from China, Canada, Mexico, and dozens of other countries — citing national emergencies related to trade deficits, fentanyl trafficking, and immigration.

The Supreme Court disagreed with this interpretation. The majority opinion held that IEEPA's language authorizes the regulation, blocking, and freezing of financial transactions and property interests. It does not extend to the imposition of customs duties on imported goods. The power to levy tariffs, the Court ruled, is a function of trade law and belongs to Congress — not to the president acting unilaterally under emergency powers.

The Bottom Line: Every tariff imposed under IEEPA authority has been declared unconstitutional. This does not affect tariffs imposed under other legal authorities (Section 301, Section 232, or the new Section 122). But the IEEPA-based tariffs — which covered hundreds of billions of dollars in annual imports — are legally void. And the duties collected under those void tariffs must be returned to the importers who paid them.

The ruling did not just change the future of trade policy. It reached backward. Every dollar collected under IEEPA tariff authority since the tariffs were first imposed is now subject to refund claims. This is not a theoretical possibility — it is a legal right. The question is not whether you are owed money. If you paid IEEPA duties, you are. The question is whether you file the right paperwork before the deadlines expire.

How Much Money Is at Stake

The scale of the IEEPA tariff refund situation is staggering. Between early 2025 and February 20, 2026, U.S. Customs and Border Protection (CBP) collected an estimated $133 billion to $175 billion in duties that were assessed under IEEPA authority.

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Key Numbers: An estimated $133–$175 billion in IEEPA duties were collected from importers since 2025. Every importer of record who paid these duties is entitled to a full refund plus interest. Interest accrues from the date of payment to the date of refund.

To put that in perspective, this is the largest mass refund event in the history of U.S. customs enforcement. It dwarfs previous tariff refund episodes by orders of magnitude. The duties were collected across virtually every product category — from electronics and auto parts to consumer goods, food products, raw materials, and industrial components.

The refund applies to every importer of record who paid duties that were assessed under IEEPA authority. This includes:

  • Large multinational corporations that import billions in goods annually
  • Mid-size manufacturers that import raw materials and components
  • Small businesses and e-commerce sellers that import finished goods for resale
  • Any company that acted as the importer of record on entries assessed IEEPA duties

The refund amount for each importer depends on the volume and value of their IEEPA-duty imports during the period. For a business importing $1 million per month in goods that were subject to a 20% IEEPA tariff, the refund could exceed $2.4 million plus interest for the roughly 12-month collection period. For larger importers, the numbers climb into the tens or hundreds of millions.

Who Qualifies for Refunds

If you paid any of the following tariffs, you are entitled to a refund:

Tariff Category Description Typical Rates Refund Eligible?
Reciprocal Tariffs Broad duties imposed on multiple countries under IEEPA as "reciprocal" trade measures 10%–50% Yes — fully refundable
Trafficking & Immigration Tariffs Tariffs imposed under IEEPA citing fentanyl trafficking and immigration emergencies 10%–25% Yes — fully refundable
China IEEPA Surcharges Country-specific IEEPA duties on Chinese goods (separate from Section 301) 20%–35% Yes — fully refundable
Canada IEEPA Duties Country-specific tariffs on Canadian goods imposed under IEEPA 25%–35% Yes — fully refundable
Mexico IEEPA Duties Country-specific tariffs on Mexican goods imposed under IEEPA 25% Yes — fully refundable
Important Distinction: Tariffs imposed under other legal authorities are not affected by the Supreme Court ruling and are not refundable. This includes Section 301 tariffs on Chinese goods, Section 232 tariffs on steel and aluminum, antidumping and countervailing duties, and the new Section 122 global tariff. Only duties specifically assessed under IEEPA authority qualify for refunds.

The critical factor is the legal basis cited on your entry documents. If the duty was assessed under IEEPA authority, it is refundable. If it was assessed under Section 301, Section 232, or another statute, it is not. Many importers had duties assessed under multiple authorities simultaneously — in those cases, only the IEEPA portion is refundable.

Two Paths to Your Refund: PSC vs. Protest

There are two legal mechanisms for recovering overpaid IEEPA duties, and which one you use depends entirely on whether your entries have been liquidated by CBP.

Liquidation is the final computation of duties owed on an import entry. CBP typically liquidates entries 314 days after the date of entry, though extensions are common. Until an entry is liquidated, it is considered "open" and can be corrected. Once liquidated, changes must go through the formal protest process.

Feature Path A: Post Summary Correction (PSC) Path B: Administrative Protest
Entry Status Unliquidated (not yet finalized by CBP) Liquidated (already finalized by CBP)
Filing Deadline Within 300 days of entry OR 15 days before scheduled liquidation Within 180 days of the liquidation date
Filing Method Amend the original entry summary through ACE (Automated Commercial Environment) File CBP Form 19 at the port of entry
Processing Speed Faster — correction is processed during normal liquidation cycle Slower — formal CBP review process, typically 12–18 months
Complexity Lower — amends existing entry data Higher — requires formal legal argumentation and documentation
Appeal if Denied Entry liquidates as originally filed; then file protest Appeal to Court of International Trade within 180 days of denial
Best For Recent entries from late 2025 and 2026 Older entries from early-to-mid 2025

Path A: Post Summary Correction (PSC)

If your entries have not yet been liquidated by CBP, the Post Summary Correction is your faster and simpler route to a refund. A PSC amends the original entry summary to remove the IEEPA-based duty assessment, and the corrected entry then liquidates at the lower (non-IEEPA) rate.

The key deadlines for PSC filing are:

  • 300 days from the date of entry, OR
  • 15 days before the scheduled liquidation date — whichever comes first

PSCs are filed electronically through the ACE system, typically by your customs broker. The correction removes the IEEPA duty line items from the entry summary and recalculates the total duties owed. When CBP liquidates the corrected entry, the overpayment is refunded.

Path B: Administrative Protest (CBP Form 19)

If your entries have already been liquidated, you must file a formal Administrative Protest using CBP Form 19. This is a more involved process, but it is the only way to recover duties on entries that CBP has already finalized.

The critical deadline is 180 days from the date of liquidation. Miss this deadline and you permanently forfeit your right to a refund on that entry.

The protest must include a detailed legal basis for the claim (the Supreme Court ruling provides this), supporting documentation, and a specific dollar amount being claimed. CBP reviews the protest and issues a decision. If the protest is approved, the refund is issued plus interest. If denied, you can appeal to the U.S. Court of International Trade within 180 days of the denial.

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Practical Tip: Many importers will have a mix of both liquidated and unliquidated entries. You will likely need to use both methods — PSCs for your more recent entries and protests for older ones. Start by pulling your full entry history and classifying each entry by liquidation status.

Step-by-Step Refund Process

Here is the complete process for recovering your overpaid IEEPA duties, from initial audit through final refund receipt.

1

Audit Your Import Records

Pull every entry summary from January 2025 through February 20, 2026. Identify all entries where duties were assessed under IEEPA authority. Look for HTS codes and duty lines that reference IEEPA executive orders, reciprocal tariff proclamations, or the specific country-based IEEPA surcharges. Your customs broker should be able to generate a filtered report from ACE showing IEEPA-specific assessments. Compile the total dollar amount of IEEPA duties paid across all entries.

2

Classify Entries: Liquidated vs. Unliquidated

For each IEEPA-duty entry, determine whether it has been liquidated by CBP. You can check liquidation status through ACE, through your customs broker's system, or by reviewing CBP bulletin notices. Entries filed within the last 10–11 months are more likely to be unliquidated. Entries from early 2025 may already be liquidated. Separate your entries into two lists: one for PSC filing (unliquidated) and one for protest filing (liquidated).

3

Gather Documentation

For each entry, assemble the following: the original entry summary (CBP Form 7501), proof of duty payment (Automated Clearinghouse records or checks), commercial invoices, bills of lading, and any broker correspondence related to the IEEPA tariff assessment. For protests, you will also need a legal brief citing the Supreme Court ruling as the basis for the refund claim. Organize documents by entry number for efficient filing.

4

File PSCs for Unliquidated Entries

Work with your customs broker to file Post Summary Corrections through ACE for every unliquidated entry that was assessed IEEPA duties. The PSC amends the entry summary to remove the IEEPA duty line items and recalculates total duties owed. Ensure each PSC is filed before the 300-day deadline or 15 days before scheduled liquidation, whichever is sooner. Prioritize entries closest to liquidation — once an entry liquidates, you lose the PSC option and must file a protest instead.

5

File Protests for Liquidated Entries

For entries that have already been liquidated, file Administrative Protests using CBP Form 19 at the port of entry where the goods were processed. The protest must be filed within 180 days of the liquidation date. Include the Supreme Court ruling citation (Learning Resources, Inc. v. Trump, decided Feb. 20, 2026), the specific entry numbers and duty amounts being protested, and all supporting documentation. If you have many liquidated entries at different ports, you may need to file multiple protests.

6

Track and Follow Up

Create a tracking spreadsheet for every PSC and protest filed, including entry numbers, filing dates, amounts claimed, and current status. Monitor ACE for PSC processing updates and liquidation notices. For protests, CBP is required to issue a decision within two years, but given the volume of claims expected, processing may take longer. If a protest is denied, you have 180 days to appeal to the Court of International Trade. Follow up with your broker monthly and escalate to a trade attorney if any deadlines are approaching without resolution.

Need Help Pulling Your Import Records?

Miami Alliance 3PL maintains detailed receiving logs and entry documentation for every shipment we handle. If you warehouse with us, we can help you reconcile your IEEPA duty entries.

Talk to Our Team

Timeline Expectations

This is the largest customs refund event in U.S. history. CBP will be processing an unprecedented volume of corrections and protests simultaneously. Here is what to realistically expect:

PSC Refunds: 3–9 Months

Post Summary Corrections are processed as part of the normal liquidation cycle. Once the corrected entry liquidates, the duty overpayment is refunded. Under normal conditions this takes a few months, but the surge in PSC filings may extend processing to 6–9 months. Entries closer to their liquidation date will be processed sooner.

Protest Refunds: 12–18+ Months

Administrative protests require formal CBP review and a written decision. CBP has two years to decide, and given the volume of IEEPA-related protests, most trade attorneys expect processing to take 12–18 months at minimum. Complex cases or cases involving large dollar amounts may take longer. Interest continues to accrue during the processing period.

Interest Accrues from Day of Payment

Under 19 U.S.C. § 1505(c), interest on duty refunds accrues from the date the duties were deposited with CBP. The interest rate is set quarterly and is based on the federal short-term rate. This means the longer processing takes, the more interest you receive. Interest is not a consolation prize — on large refund amounts over 12–18 months, it can add meaningfully to your total recovery.

CBP May Issue Bulk Guidance

Given the scale and uniformity of these claims (all based on the same Supreme Court ruling), CBP may issue a blanket instruction to liquidate or reliquidate IEEPA entries at zero duty. This would dramatically accelerate the refund process. Trade associations are actively lobbying for this approach. Monitor CBP Federal Register notices and trade publications for updates.

Common Mistakes to Avoid

The refund process is straightforward in principle but unforgiving in execution. Here are the most common errors that can delay or destroy your refund claim:

Missing Deadlines

This is the single biggest risk. The 180-day protest window and the 300-day PSC window are hard deadlines — once they pass, your right to a refund on that entry is gone permanently. Do not assume CBP will extend deadlines or create special accommodations. Start your audit and filing process immediately. The earliest IEEPA entries from early 2025 may have protest deadlines approaching in the next few months.

Incorrect Entry Classification

Filing a PSC on an entry that has already been liquidated will be rejected. Filing a protest on an entry that has not yet been liquidated is premature and wasteful. You must accurately determine the liquidation status of every entry before choosing your filing method. Check ACE or consult your broker — do not guess.

Incomplete Documentation

A protest without complete supporting documentation will be denied or delayed. Every claim needs the entry summary, proof of payment, and a clear legal basis. Vague or generalized filings that do not tie the claim to specific entry numbers and dollar amounts will be returned for correction — potentially eating into your deadline window.

Confusing IEEPA Duties with Other Tariffs

Only duties assessed under IEEPA authority are refundable. Section 301 tariffs on Chinese goods, Section 232 tariffs on steel and aluminum, antidumping and countervailing duties, and the new Section 122 global tariff are all still valid and not subject to refund. If you claim a refund on non-IEEPA duties, your entire filing may be rejected. Verify the legal basis of each duty assessment before including it in your claim.

Waiting for CBP to Act on Its Own

Do not assume CBP will proactively refund overpaid IEEPA duties without a filing from you. While CBP may eventually issue blanket reliquidation guidance, there is no guarantee of when — or if — that will happen. The safe approach is to file your claims now. If CBP issues bulk relief later, your individual filings become moot. If they do not, you have protected your rights.

How Your 3PL Warehouse Partner Helps

Filing IEEPA refund claims requires one thing above all else: organized, complete import records. And that is precisely where a well-run 3PL warehouse proves its value beyond day-to-day logistics.

Organized Import Records

Every shipment that arrives at a 3PL warehouse is logged with detailed receiving documentation — including entry numbers, container numbers, arrival dates, and quantities. These records create a parallel trail that helps you reconcile CBP entry data against physical goods received. When you need to prove that a specific entry was assessed IEEPA duties and that the goods were actually imported, your 3PL's receiving logs provide critical corroboration.

Entry Documentation Access

Many 3PL operations maintain copies of entry summaries, commercial invoices, and packing lists as part of their standard receiving process. If your own records are incomplete — or if your customs broker's archives are difficult to access — your 3PL's files may contain the documents you need to assemble your refund claim.

Customs Broker Coordination

A 3PL that handles imports regularly has established relationships with customs brokers who understand the PSC and protest process. Your warehouse partner can facilitate introductions, help coordinate documentation assembly, and ensure that your broker has access to the warehouse-side records needed to complete filings efficiently.

Inventory Reconciliation

For refund claims involving large numbers of entries, reconciling import records against inventory can help identify entries you might otherwise miss. Your 3PL's inventory management system tracks what came in, when, and from where — data that can be cross-referenced with your duty payment records to ensure no refundable entry is overlooked.

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Miami Alliance 3PL Advantage: We maintain detailed digital records for every shipment we receive, including entry summaries, BOLs, receiving timestamps, and inventory logs. Our team can help you pull records for any shipment that passed through our facility during the IEEPA tariff period. Contact us to start the documentation process.

Frequently Asked Questions

How do I get a refund for IEEPA tariffs I already paid?

There are two paths depending on the status of your entries. For unliquidated entries, file a Post Summary Correction (PSC) within 300 days of entry or 15 days before scheduled liquidation. For liquidated entries, file an Administrative Protest (CBP Form 19) within 180 days of the liquidation date. Both methods require supporting documentation including entry summaries, duty payment receipts, and proof that duties were assessed under IEEPA authority. Work with your customs broker to determine which path applies to each of your entries.

How much money is at stake in IEEPA tariff refunds?

Between $133 billion and $175 billion in IEEPA-based duties were collected from importers between early 2025 and February 20, 2026. Every importer of record who paid these duties is entitled to a full refund plus interest. The exact amount each importer can recover depends on the volume and value of their imports during this period. For a business that imported $1 million per month at a 20% IEEPA rate, the refund could exceed $2.4 million plus interest.

What is the deadline to file an IEEPA tariff refund claim?

Deadlines depend on the status of your entries. For unliquidated entries, you must file a Post Summary Correction within 300 days of the entry date or at least 15 days before the scheduled liquidation date. For liquidated entries, you must file a CBP protest within 180 days of the liquidation date. Missing these deadlines means permanently forfeiting your right to a refund on that entry. Importers should audit their records and begin filing immediately.

What is the difference between a Post Summary Correction and a CBP protest?

A Post Summary Correction (PSC) is used for entries that have not yet been liquidated (finalized) by CBP. It is a faster, simpler process that amends the original entry summary. A CBP Administrative Protest (filed on Form 19) is required for entries that have already been liquidated. The protest is a formal review process where CBP evaluates your claim and issues a decision. PSCs are generally processed faster (3–9 months), while protests can take 12–18 months or longer.

Can my 3PL warehouse help with IEEPA tariff refund claims?

Yes. A well-organized 3PL partner maintains detailed import records including entry summaries, receiving logs, duty payment documentation, and customs broker correspondence. These records are essential evidence for refund claims. Your 3PL can help you reconcile inventory against import entries, identify all shipments that were assessed IEEPA duties, and coordinate with your customs broker to assemble the documentation needed for PSC filings or protests.