When the Supreme Court ruled in Learning Resources v. Trump on February 20, 2026, that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful, it opened the door to billions of dollars in refunds for U.S. importers. With roughly $166 billion at stake and more than 333,000 businesses affected, the question most importers are asking isn’t whether refunds exist. It’s whether they qualify for one.
The answer depends on a handful of specific factors. Here’s how to tell if your business is likely eligible.
The Four Questions That Determine Your Eligibility
1. Were You the Importer of Record?
Refunds generally go to the importer of record, the party listed on the customs entry and responsible for paying the duties. If you bought goods from a domestic distributor who handled the importing, the refund most likely belongs to them, not you. If your company’s name or customs bond appears on the entry paperwork, you’re in the right position to claim.
2. Did You Pay Duties During the IEEPA Window?
Only duties paid on goods entered between February 4, 2025, and February 24, 2026, fall under the ruling. Imports entered before or after that period aren’t covered, even if you paid other tariffs on them.
3. Were the Duties Actually IEEPA Tariffs?
This is where many importers get tripped up. Not every tariff collected during that window was imposed under IEEPA. Section 301 duties, Section 232 duties on steel, aluminum and other products, antidumping and countervailing duties, and Section 122 tariffs are all excluded. A single entry can carry several types of duties, so each line item needs to be reviewed to separate refundable amounts from non-refundable ones.
4. Is Your Claim Still Within the Deadlines?
Eligibility isn’t only about what you paid. It’s also about when you act. CBP is processing refunds through its new CAPE system, and entries that have already liquidated may require a formal protest, generally within 180 days of liquidation. Miss that window, and a valid claim can become far harder, or even impossible, to recover.
If you answered yes to the first three questions, there’s a strong chance your business is owed money. Most importers are small businesses without the time to comb through hundreds of entries line by line, and assuming a customs broker or freight forwarder has already taken care of everything can be a costly mistake.
The most reliable way to confirm eligibility is to bring in a tariff recovery consultant who can audit your entries line by line and map out your deadlines. Eligibility is only the first step, but confirming it early gives you the best chance of recovering every dollar you’re owed.
