IEEPA Tariff Refunds for Amazon Sellers: Who Gets the Money and What to Do Now

If you imported inventory between early 2025 and February 2026, U.S. Customs may be holding money that belongs to you. Or to your supplier. Or to your freight forwarder. IEEPA tariff refunds are real, they are being paid, and for many Amazon sellers they are the largest one-time cash event of the year. But the refund goes to exactly one party, and a lot of brand owners are finding out the hard way that it isn't them.

Timeline: The Supreme Court struck down the IEEPA tariffs on February 20, 2026. CBP's refund system opened April 20, 2026, and Phase 3 was scheduled for October 6, 2026. Current as of October 2026.

Here is what happened, who qualifies, and what we'd do this week if it were our inventory. One caution up front: this is customs and legal territory, the rules have shifted several times since February, and the details for your entries belong with your customs broker, trade attorney and CPA. Treat this as the map, not the ruling.

What happened to the IEEPA tariffs?

On February 20, 2026, the U.S. Supreme Court decided Learning Resources, Inc. v. Trump (consolidated with Trump v. V.O.S. Selections) and held 6-3 that the International Emergency Economic Powers Act does not authorize the President to impose tariffs. That knocked out two sets of 2025 duties: the drug-trafficking tariffs on most goods from Canada, Mexico and China, and the "reciprocal" tariffs on imports from nearly every trading partner.

U.S. Customs and Border Protection (CBP) stopped collecting IEEPA duties on goods entered for consumption at or after 12:00 a.m. Eastern on February 24, 2026.

That did not make imports tariff-free. The same day, a temporary 10% surcharge under Section 122 of the Trade Act of 1974 took effect. A 15% rate was announced but, according to the trade counsel and analysts we checked, never implemented. Section 122 is capped at 150 days, so it lapsed on July 24, 2026, and new Section 301 duties of 10% or 12.5% on roughly 60 economies took its place that day. China carries its own separate Section 301 duties. Section 232 duties (steel, aluminum and the rest) and antidumping and countervailing duties were never part of the IEEPA case and still apply.

So the refund question is about the past. Your landed cost today is a different calculation, and it is worth redoing before you reorder.

Who is eligible for IEEPA tariff refunds?

The importer of record (IOR). That is the party named on CBP Form 7501, the entry summary, who was legally responsible for paying the duty. Not the brand. Not whoever ultimately absorbed the cost.

For Amazon sellers it usually sorts out like this:

• You are probably the IOR if you bought from an overseas factory and shipped under your own importer number, whether straight into FBA or through a U.S. warehouse first. Amazon is explicit that it will not act as importer of record for FBA inventory: you, or an entity you appoint, has to. That holds when you use Amazon Global Logistics, too.

• You are probably not the IOR if you bought from a U.S. distributor or wholesaler, bought on a landed or delivered price, or your supplier shipped DDP (delivered duty paid) using its own importer number. In those cases the refund goes to whoever is on the 7501.

• You may not be the IOR even when you think you are if a freight forwarder or a third party served as IOR on your behalf. This is common with small importers, and it is the first thing to check.

A concrete example. Two brands sell the same trekking pole. One buys FOB from a factory in Ningbo and imports under its own IOR number. The other buys DDP, so the factory's U.S. agent clears customs. Both paid the tariff in the sense that it was baked into their cost. Only the first one files for the refund. The second brand's only route to that money is commercial: a conversation, or a contract, with its supplier. That is a question for your attorney, not for CBP.

How the IEEPA refund process works

CBP built a dedicated system for this called CAPE (Consolidated Administration and Processing of Entries), inside the ACE Portal. Per CBP's IEEPA refund page:

• Only the importer of record, or the licensed customs broker who filed the entries, can submit a CAPE Declaration. In practice, the importer or broker uploads a list of entry numbers and CBP recalculates duties as if the IEEPA tariffs had never applied.

• Refunds are paid by ACH only. If your bank details aren't set up for refunds in the ACE Portal, CBP holds the money.

• CBP says valid refunds generally issue within 60 to 90 days after a declaration is accepted, and interest is included.

• Post-summary corrections are not the route for IEEPA refunds.

CAPE has rolled out in phases:

1. Phase 1 (April 20, 2026): unliquidated entries, plus entries within 80 days of liquidation.

2. Phase 2 (June 29, 2026): entries flagged for reconciliation with no reconciliation entry on file.

3. Phase 3 (CBP scheduled it to open October 6, 2026): entries liquidated more than 80 days ago, but only for importers who have their own IEEPA refund case pending at the U.S. Court of International Trade (CIT).

The money is moving. In a court filing reported in August, CBP said it had paid about $100 billion in IEEPA refunds as of July 31, 2026.

The catch: older entries and the 80-day line

"Liquidation" is Customs' final accounting on an entry, and by default it happens roughly a year after the goods arrive. The IEEPA tariffs started in early 2025, which means many of the earliest entries have already liquidated, and plenty are now past the 80-day mark that Phase 1 covers.

For those finally liquidated entries, the path right now runs through the CIT. Phase 3 is open only to importers with a pending case there. The government appealed the CIT's broader refund order to the Federal Circuit in June 2026, arguing that importers who never sued should not get refunds on these entries. Separately, the CIT is weighing a motion to certify a nationwide class in V.O.S. Selections, Inc. v. United States (argued August 6, 2026), which could let non-plaintiff importers recover on finally liquidated entries without suing individually. Neither question was resolved as of early October 2026. Both are moving, so check the current status with your customs broker before you act.

Here is why that matters to a seller who imported a few containers of camp cookware in spring 2025: those entries may be exactly the ones that fall outside the simple path. Trade lawyers are also flagging filing deadlines for CIT suits that run from each entry's date, so waiting has a cost. Whether a suit makes sense for your volume is a judgment call for a trade attorney, and for some smaller importers the math won't support it. Get the number first, then decide.

What to do this week

1. Confirm who the importer of record was. Pull your 7501s or ask your forwarder or broker directly. Do this per shipment, since it can vary.

2. Get a report of IEEPA duties paid, by entry. Your customs broker can produce it. If Amazon's customs brokerage cleared your Amazon Global Logistics shipments, ask there.

3. Check ACH refund setup in the ACE Portal. No ACH, no refund.

4. Ask your broker what has been filed in CAPE, which entries were accepted, and which were rejected and why.

5. Sort the rest by liquidation status. Unliquidated and recently liquidated entries go through CAPE. Finally liquidated entries need a conversation with a trade attorney about the CIT.

6. If you weren't the IOR, review your purchase terms and talk to your supplier and your attorney.

7. Ask your CPA how to book it. Refunded duty may touch cost of goods for inventory you sold in prior periods, and the timing affects taxes.

One more thing, and it's the operator in us talking. Don't spend the refund before it lands, and don't treat it as margin. It is a one-time cash recovery on costs you already ate. Cutting price on the strength of a refund check is how a good quarter becomes a bad year. The better use is to pay down what the tariffs forced you to borrow, then rebuild your landed cost at today's Section 301 rates alongside your full Amazon fee load.