The Supreme Court struck down $166 billion in IEEPA tariffs. If you're an importer with a claim, you need to know its value - whether you're holding, selling, or negotiating.
Price My Claim →An IEEPA tariff refund is the repayment of customs duties collected under the International Emergency Economic Powers Act that the Supreme Court ruled unconstitutional on February 20, 2026. It works by filing through one of three recovery paths — unliquidated entries, protests under 19 USC §1514, or 1581(i) actions in the Court of International Trade. The total refund pool is estimated at $166 billion by the Penn Wharton Budget Model. TariffRefundIQ helps importers calculate the probability-weighted expected value of their individual refund claims.
On February 20, 2026, the 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. The ruling strikes down all IEEPA-based tariffs - including those on China, Canada, Mexico, and the "Liberation Day" reciprocal tariffs.
The Penn Wharton Budget Model estimates $166 billion in potential refund liability. However, the Court did not explicitly order refunds - it remanded to the Court of International Trade (CIT) to address remedy.
Hours after the ruling, President Trump held a press conference stating his administration would litigate refunds for "2 to 5 years" and simultaneously signed executive orders imposing replacement tariffs under Section 122 and initiating Section 301 investigations. These new tariffs are prospective only - they do not affect the obligation to refund past IEEPA collections.
Only tariffs imposed under IEEPA authority are eligible for refund after the Supreme Court ruling. Section 232 and Section 301 tariffs remain in effect because they were authorized under different statutes.
| Tariff | Legal Authority | Rate | Refund Eligible? |
|---|---|---|---|
| China fentanyl tariffs | IEEPA | 20% – 145% | Yes |
| Canada/Mexico border tariffs | IEEPA | 25% | Yes |
| Liberation Day reciprocal tariffs | IEEPA | 10% – 50% | Yes |
| Steel & aluminum tariffs | Section 232 | 25% | No |
| Original China tariffs (Lists 1–4) | Section 301 | 7.5% – 25% | No |
The IEEPA tariff refund timeline spans from the original tariff imposition in 2025 through the Supreme Court ruling and ongoing CIT proceedings in 2026.
| Date | Event |
|---|---|
| Feb 1, 2025 | IEEPA fentanyl tariffs on China take effect (initial 10%) |
| Mar 4, 2025 | IEEPA border tariffs on Canada/Mexico take effect (25%) |
| Apr 9, 2025 | Liberation Day reciprocal tariffs take effect (10%–50% by country) |
| Feb 20, 2026 | Supreme Court rules 6-3 in Learning Resources v. Trump that IEEPA does not authorize tariffs |
| Feb 20, 2026 | President signs replacement tariffs under Section 122 and initiates Section 301 investigations |
| Mar 4, 2026 | CIT orders CBP to begin processing refunds on all IEEPA tariff entries |
| Mar 20, 2026 | CIT expands scope to ALL IEEPA tariffs including Brazil and India imports (excludes de minimis entries) |
| Mar 27, 2026 | CIT orders reliquidation of finally liquidated entries — entries beyond 180-day protest window now eligible |
| Apr 1, 2026 | CIT confirms government on track to meet April 20 CAPE Phase 1 launch deadline |
| Apr 20, 2026 | CAPE Phase 1 target launch — covers ~63% of all IEEPA entries (unliquidated + within 90-day voluntary reliquidation window) |
| ~Mar 20, 2026 | Federal Circuit appeal deadline passes — DOJ does not file appeal. Government posture shifts to "comply with process, contest scope" |
| Apr 14, 2026 | CBP status report due (noon EDT) + closed conference with Judge Eaton (3:00 PM EDT) — last checkpoint before April 20 launch |
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The SCOTUS ruling created $166B in potential refund claims. Litigation buyers are already circling.
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