IEEPA Duty Refund Update
Apr 18, 2026

Recent legal developments surrounding tariffs imposed under the International Emergency Economic Powers Act (IEEPA) have created potential opportunities for certain importers to recover duties previously paid. For PRINTING United Alliance members—many of whom rely on globally sourced inputs such as paper, inks, substrates, and equipment—understanding the scope and limitations of these potential refunds is critical. While the ruling may offer financial relief in specific circumstances, it also introduces complexity in determining eligibility, documentation requirements, and the practical likelihood of recovery.

Importantly, tariff refunds are not universally available across the supply chain. Refund eligibility is generally limited to importers of record that directly paid duties under the invalidated IEEPA framework; downstream buyers, including many print service providers and converters, are typically not eligible to claim refunds. Additionally, not all tariffs are affected. Duties imposed under authorities such as Section 301, Section 232, and antidumping or countervailing duty regimes remain in place and are not eligible for recovery through U.S. Customs and Border Protection (CBP) processes tied to IEEPA. Even within potentially eligible entries, factors such as duty drawback claims, reconciliation filings, and overlapping trade programs may complicate or preclude recovery.

To pursue a successful refund, importers must meet two core requirements: demonstrating that the tariffs were paid under the invalidated IEEPA authority and substantiating that the amounts claimed are accurate and fully supported. U.S. Customs and Border Protection is expected to closely scrutinize claims, with particular attention to classification, valuation, and country-of-origin data. As a result, maintaining complete and consistent documentation is essential—especially for liquidated entries, where the evidentiary burden is higher.

Given the complexity and fact-specific nature of these claims, Alliance members are strongly encouraged to consult with their customs broker and/or legal counsel to evaluate their specific circumstances and determine the most appropriate path forward. This document outlines the key considerations, limitations, and practical steps for navigating the tariff refund landscape: IEEPA Refund Update 4.15.26

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