Do I have to be the Importer of Record?

In most cases, yes. The Importer of Record is the party legally responsible for the customs entry and payment of duties. If a consolidator or third party acted as the Importer of Record, a review may be needed to determine the appropriate path forward.

What should I do if I'm not sure whether I qualify?

Schedule a Guidance Call. Tariff Refund Processing Center will help you understand your situation and connect you with the appropriate Tariff Refund Agency team for a formal review.

Tariff Refund Resource Center

Who Qualifies for an IEEPA Tariff Refund?

Q: Who qualifies for an IEEPA tariff refund?

Generally, the Importer of Record who paid eligible IEEPA duties on qualifying entries may qualify. Eligibility depends on the specific customs entries, applicable tariff provisions, and whether filing deadlines have been met.

Q: Do all tariffs qualify?

No. Only certain IEEPA duties may qualify. Programs such as Section 301, Section 232, and AD/CVD follow different legal frameworks and should not be assumed to qualify for this program.

Learn the key factors that may determine whether your business qualifies for an IEEPA tariff refund, including Importer of Record status, eligible duties, and filing deadlines.

SEE IF YOU MAY QUALIFY SCHEDULE A GUIDANCE CALL

Learn the three primary eligibility requirements

Understand Importer of Record requirements

See which duties may qualify

Determine your next step if you may be eligible

Last Updated: August 2026·Reviewed and updated to reflect the latest Tariff Refund Agency educational guidance.

The Simple Answer

Whether an importer may qualify for an IEEPA tariff refund generally depends on three key factors:

The business was the Importer of Record for the applicable entries.
The customs entries included potentially eligible IEEPA duties.
The applicable filing opportunity is still available based on the entry's liquidation status and filing deadline.

Eligibility is determined entry by entry. Tariff Refund Agency reviews the relevant import data and documentation to determine which opportunities may qualify and which filing path may apply.

Quick Summary

Best For

Importers, customs brokers, and referral partners evaluating potential tariff refund eligibility.

You'll Learn

The three primary factors that may determine whether an importer qualifies for an IEEPA tariff refund.

Next Step

If your situation appears to meet the basic requirements, review filing deadlines or begin the Tariff Refund Application.

Who Should Read This?

This guide is designed for businesses and professionals trying to determine whether an IEEPA tariff refund opportunity may apply.

Importers

Determine whether your company may meet the basic requirements for an IEEPA tariff refund.

For Importers

Customs Brokers

Understand the key eligibility factors so you can identify potential tariff refund opportunities for clients.

For Customs Brokers

Referral Partners

Learn the basic eligibility criteria so you can recognize businesses that may benefit from an introduction to Tariff Refund Agency.

Partnership Opportunities

Key Takeaways

Importer of Record status matters.

Not every tariff qualifies.

Eligibility is evaluated entry by entry.

Filing deadlines can determine whether an opportunity remains available.

Tariff Refund Agency reviews the applicable data and determines the appropriate next step.

Three Key Factors That May Determine Eligibility

A business may need to satisfy several requirements before an IEEPA tariff refund can move forward.

Importer of Record Status

The entity seeking the refund generally must be the Importer of Record associated with the customs entry. The Importer of Record is the party legally responsible for the import entry and payment of applicable duties.

Learn About Importer of Record

Eligible IEEPA Duties

Not every tariff or customs duty qualifies. Eligibility depends on the specific duties applied to the customs entry and whether those duties fall within the applicable IEEPA tariff refund framework.

Programs such as Section 301, Section 232, and AD/CVD follow different legal frameworks and should not be presented as automatically qualifying for this program.

Filing Timing

Each customs entry follows its own liquidation and filing timeline. If an applicable filing deadline has passed, the opportunity for that entry may be limited or unavailable.

Understand Filing Deadlines

Could Your Business Qualify?

Were you the Importer of Record?

✓YES → Continue

?NO / UNSURE → Schedule a Guidance Call

Did the entries include potentially eligible IEEPA duties?

✓YES → Continue

?UNSURE → Tariff Refund Agency can review the applicable data.

Is the filing opportunity still available?

✓YES → You may have an eligible tariff refund opportunity.

?UNSURE → Review filing deadlines.

You May Qualify

This checklist is only a starting point. Final eligibility depends on the specific entries, duties, documentation, and applicable filing path.

START MY TARIFF REFUND APPLICATION SCHEDULE A GUIDANCE CALL

What You May Need to Verify Eligibility

You do not need every document before starting, but these records may help Tariff Refund Agency evaluate your situation more efficiently.

Importer of Record Number

Your Importer of Record number helps identify the relevant customs entries.

ACE Entry Data

ACE reports can help identify entries, liquidation dates, and applicable duties.

CBP Form 7501

Entry Summary forms may help confirm the Importer of Record and duty information.

You may begin even if all documents are not immediately available.

Common Reasons Businesses Think They Don't Qualify

Some of the most common concerns do not automatically eliminate a potential tariff refund opportunity.

My customs broker handled everything.

That's common. Using a customs broker does not automatically mean the broker was the Importer of Record. The applicable entry documentation determines who held that role.

My imports were months ago.

That does not automatically mean the opportunity is gone. Each entry follows its own filing timeline.

I don't know which tariffs I paid.

Many importers do not know which tariff provisions were applied to individual entries. Tariff Refund Agency can review the relevant import data to determine which duties may require further evaluation.

I don't have all my paperwork.

You can still begin the process. Additional documentation can be gathered if your situation moves forward.

How Tariff Refund Agency Reviews Potential Eligibility

Importer of Record Verification

Confirm the entity associated with the customs entry.

Duty Review

Review the applicable duties and tariff provisions.

Entry Timeline Review

Identify liquidation dates and important filing deadlines.

Documentation Review

Review available ACE data, Form 7501s, and other relevant records.

Filing Path Determination

Determine which filing pathway may apply to each eligible entry.