If your business imported anything in 2025 or early 2026 and paid tariffs under the International Emergency Economic Powers Act, U.S. Customs and Border Protection may owe you money — and the final phase of the refund program is now opening. As of July 10, 2026, CBP had accepted roughly $121.75 billion in refund claims and repaid about $86.3 billion to importers, including statutory interest.
The catch is a deadline most small importers have never had to think about: 180 days from the date an entry liquidates. After that, the entry is administratively final, and no refund claim can reopen it. Not the import date. Not the date you paid. The liquidation date.
What happened
The Supreme Court struck down the IEEPA-based tariffs in February 2026. CBP responded by building a dedicated refund channel rather than routing claims through the ordinary process, and rolled it out in phases:
- Phase 1 — launched April 20, 2026: unliquidated entries and entries less than 80 days past liquidation.
- Phase 2 — opened June 29, 2026: entries flagged for reconciliation, same eligibility rules as Phase 1.
- Phase 3 — on track for late July 2026: finally liquidated entries that didn’t qualify for Phase 1, meaning those more than 80 days past liquidation.
Claims run through CBP’s Automated Commercial Environment system, and the agency has published a dedicated IEEPA Duty Refunds page. Per importer guidance from Dimerco, once CBP removes the IEEPA duties it transmits refunds to Treasury within roughly 14–16 days, with about two business days from Treasury to the importer’s account — assuming ACH enrollment and banking details are current.
For entries already past the Phase 1 window, the mechanism is a customs protest under 19 U.S.C. § 1514, which must be filed within 180 days of liquidation. Filing the protest keeps the entry open for a future refund claim. Letting the window close ends the matter.
The money is reaching real businesses, slowly. KSAT reported July 30 on Monarch Trophy Studio, a San Antonio shop pursuing refunds on Chinese imports with help from its shipping provider. Owner Charlie Drago described the squeeze plainly: at one point the shop was “selling the product cheaper to the customer than we paid for it.”
If we get a rebate on tariffs, it’s like Christmas.
— Charlie Drago, Monarch Trophy Studio, via KSAT
One caveat worth stating clearly: the administration has appealed aspects of the refund orders, which introduces some uncertainty around the Phase 3 rollout. That’s a reason to file and preserve your position now, not a reason to wait and see.
Why it matters
Large importers have customs brokers watching liquidation dates as a matter of routine. Small importers usually don’t — and liquidation isn’t a date that appears on any invoice or bank statement. It’s a customs event that happens quietly, typically about a year after entry, and it starts a clock nobody sends you a reminder about.
That asymmetry is why a meaningful share of the outstanding refunds may never be claimed. The tariffs were ruled unlawful; the money is appropriated and moving; and the businesses least equipped to track a technical customs deadline are the ones most likely to miss it. Note also that the earlier IEEPA refunds are separate from the Section 301 tariffs that took effect in late July — those are a different regime, currently being challenged in court, and are not part of this refund program.
What this means for small-business owners
Find out whether you’re an importer of record. If you buy overseas through a domestic distributor, you probably aren’t and this doesn’t apply. If you import directly — even in small volumes, even via a freight forwarder — you likely are, and you have entries in ACE with your name on them.
Pull your liquidation dates this week. Your customs broker or freight forwarder can run the ACE reports (Rev-603, Rev-613, Rev-615, and Es-022) that show entry and liquidation dates. This is the single most time-sensitive step: any entry approaching 180 days past liquidation needs a protest filed before that window closes.
Start with your shipping provider. The practical path for most small importers is exactly what the San Antonio shop did — contact the carrier or broker who handled the entries, gather invoices and supporting documentation, and file through CBP’s IEEPA Duty Refunds portal at cbp.gov.
Verify your ACH details before the refund clears. Refunds move fast once approved. Stale banking information in your CBP profile is an avoidable way to turn a two-day transfer into a months-long problem.
Book the refund correctly. If you expensed the tariffs as cost of goods sold when paid, the refund generally reverses that expense in the period received — it isn’t revenue. Statutory interest is treated separately as interest income. Getting this wrong distorts both your gross margin and your taxable income, and it’s an easy fix if you flag it to your bookkeeper before the deposit lands rather than after.
The bottom line
Roughly $86.3 billion has already gone back to importers, and the last phase of the program is opening now. For a small business that absorbed tariffs it couldn’t pass through to customers, this is real recoverable cash — but it’s governed by a deadline measured from a date most owners have never looked up. Pull your liquidation dates, file what needs filing, and decide how you’ll book it before the money arrives.
