Before you decide whether an IEEPA tariff refund is worth pursuing, you need a real number.
Not an industry estimate. Not a percentage of your imports. The actual refund amount for your specific entries.
That number comes down to how much you paid in IEEPA duties, how much interest accrued since you paid, and how many of your entries are still within an active refund window.
Here's how the math works, what drives the amount up or down, and why most online calculators can't give you a real answer.
For background on which duties are refundable, see IEEPA vs. Section 301 Tariffs: What's the Difference?.
At the entry level, the math is simple.
Refund amount = (IEEPA duty rate × dutiable value) + accrued interest
For each eligible entry, you need three numbers:
Multiply the duty rate by the dutiable value. That's your principal refund on the entry. Add the accrued interest. That's the total recovery.
Repeat for every eligible entry.
Most businesses underestimate their refund for three reasons.
IEEPA refunds include statutory interest accruing from the date CBP collected the duties to the date the refund is issued. Across hundreds of entries spanning 12 months or more, interest can add meaningfully to the total.
A business that imported weekly across 2025 likely has hundreds of entries. Most don't pull the full list. They estimate based on what they remember.
Businesses looking at total tariffs paid often include Section 301, Section 232, and base MFN duties in their estimates. Only the IEEPA portion is refundable.
The third point is the most common source of confusion. A business that paid $2 million in total tariffs on Chinese goods during 2025 did not pay $2 million in IEEPA tariffs. Some of that was Section 301. Some may have been Section 232 on specific materials.
For more on how to separate IEEPA duties from other duty lines, see IEEPA vs. Section 301 Tariffs: What's the Difference?.
IEEPA tariffs applied from February 4, 2025, through February 24, 2026. Roughly 12 months.
The more entries you filed during that window, the larger your potential refund. A business with $10M in annual imports, paying an average 10% IEEPA duty rate, has $1M+ in principal recovery potential before interest.
Volume is the biggest driver of the total.
IEEPA duty rates weren't uniform. They varied by country of origin and by executive order.
Chinese goods faced different IEEPA rates than goods from Canada, Mexico, or other countries covered under the reciprocal tariff framework. Some rates changed during the 12-month period.
To calculate your refund accurately, each entry needs to be evaluated against the IEEPA rate that applied on its specific entry date.
Not all entries are recoverable right now.
Entries still within the CAPE Phase 1 window (unliquidated or within the preceding 80 days of liquidation) are the most straightforward. Entries past that window may still be recoverable through a formal CBP protest within 180 days of liquidation. Entries past the 180-day protest deadline don't have a current pathway.
Your recoverable refund is the total across entries where a pathway is still open.
For more on how the deadlines work, see IEEPA Tariff Refund Deadline: What Importers Need to Know.
Refunds are calculated from CBP Form 7501 (Entry Summary) data. Every eligible entry needs documentation showing the dutiable value, the HTS classification, and the IEEPA duty line.
Gaps in records limit recovery. An entry you can't document is an entry you can't claim. Most businesses don't keep their own Form 7501s. Their customs broker does. Request complete records early.
Statutory interest on IEEPA refunds accrues from the date the duties were paid to the date the refund is issued.
This matters more than it sounds.
A business that paid $500,000 in IEEPA duties in April 2025 has been accruing interest for over a year. Depending on the applicable rate, that's tens of thousands of dollars added to the refund, on top of the principal.
Across a large import history, interest can add 5% to 10% or more to the total recovery, depending on when the duties were paid and when the refund is processed.
Interest is taxable separately from the principal refund. Worth knowing before the check arrives.
Plenty of online tools will spit out an estimated refund amount based on your total imports and an assumed duty rate.
Those tools have three blind spots.
Most calculators assume your total tariff exposure is recoverable. It isn't. Only the IEEPA portion qualifies.
Whether an entry is recoverable at all depends on where it sits in the liquidation timeline. A calculator can't know that from a total imports figure.
Some businesses have HTS misclassifications, valuation errors, or missed Section 301 exclusions that a full review would catch, but a calculator can't.
An oversimplified estimate can create a false ceiling or a false floor. A calculator might say your refund is worth $80,000 when an entry-by-entry audit would show $300,000. It might also suggest $400,000 when the actual recoverable amount is $120,000 because most of your duties were Section 301.
A real number requires real analysis of your real entries.
Some importers have received offers from third parties to buy their tariff refund rights in exchange for immediate cash.
The appeal is obvious: no waiting, no paperwork, no risk of the refund getting denied.
The tradeoff is significant. Buyers typically pay a fraction of the claim's projected value. Reported transactions range from roughly 25 cents on the dollar for distressed or early sales to around 75 cents on the dollar for more recent ones. Selling also triggers tax consequences and can create contractual complications with your customers and distributors.
The decision to sell should come after a full valuation of your claim, not before. Knowing your actual refund amount positions you to negotiate from strength, or to decide the claim is better pursued directly.
If you want a rough number before engaging anyone, here's a defensible approach:
This gets you an order-of-magnitude figure. A real claim calculation requires entry-level review.
How much can my business realistically recover?
It depends on your import volume during the IEEPA period, the duty rates assessed, and how many of your entries are still within an active refund window. For a business with six- or seven-figure IEEPA duty payments, the refund is usually in the same range, plus accrued interest.
Does the refund include interest?
Yes. Statutory interest accrues from the date the duties were paid to the date the refund is issued. On large refunds, interest can add 5% to 10% or more to the total recovery.
Is there a tariff refund calculator I can use?
Basic calculators exist but have significant limitations. They can't separate IEEPA duties from Section 301 or other duties, they can't account for entry-level liquidation status, and they can't identify additional overpayment categories. Useful for rough estimates only.
Can I recover Section 301 or Section 232 duties too?
No. Only IEEPA duties are refundable under the court-ordered refund program. Section 301 duties remain owed. Section 232 duties remain owed. If your entries included multiple duty layers, only the IEEPA portion is part of this refund.
Will I owe tax on the refund?
Generally yes. The refund itself is usually taxable as ordinary income, and the statutory interest component is taxed separately as interest income. For details on the tax treatment, see How to Determine Importer of Record for IEEPA Tariff Refunds.
What if my records are incomplete?
Most businesses don't keep their own Form 7501s. Their customs broker does. Request copies for every entry in the IEEPA period. Incomplete records limit recovery, so it's worth starting the document collection early.
Should I accept an offer to sell my refund rights?
Not before you know what the refund is actually worth. Buyers typically pay a fraction of the claim value. Decide after a real valuation, not before.
Most importers who start looking into IEEPA refunds discover their exposure is larger than they expected, and that they're closer to losing parts of it than they realized.
The first step isn't filing. It's knowing the number.
Ayar Law reviews your actual import records, calculates your refund entry by entry, and shows you exactly what your business is owed (including accrued interest) before any commitment. We handle the entire filing process on pure contingency. No upfront fees. We're paid only when you are.
Call us directly: (248) 262-3400
