Article
Prepare for IEEPA tariff refunds: Start with this checklist
March 10, 2026 · Authored by Tosca Derrick
If your organization is evaluating its tariff refund eligibility, the most important step isn’t waiting for guidance — it’s preparing your records, controls and governance framework now to avoid delays and scrutiny later.
No process for seeking financial recovery has emerged since the Supreme Court’s Feb. 20, 2026, ruling that invalidated tariffs imposed under the International Emergency Economic Powers Act (IEEPA). But early preparation can reduce execution risk once formal refund procedures are announced.
It’s important to note that refund programs often generate high claim volumes and increased administrative scrutiny. Organizations that prepare early are better positioned to submit timely, well-supported claims. You could also avoid delays caused by data gaps or inconsistent methodologies.
To that end, approach your preparation as both a financial recovery initiative and a compliance exercise.
What to prepare for potential IEEPA tariff refunds
Start by determining your company’s eligibility. Then, gather documentation and implement or shore up actions grounded in existing law and Customs and Border Protection (CBP) procedures.
Your first step: A comprehensive, accurate data set.
Documentation checklist
- All entries subject to IEEPA tariffs.
- Proof of payment (including ACH/PMS records).
- Commercial documentation such as purchase orders, invoices and payment confirmations.
- Alignment across customs filings, tax records, transfer pricing documentation and financial statements.
Activity checklist
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Navigating the IEEPA tariff ruling: What importers should do now
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