What Aussie Exporters Should Know About IEEPA Tariff Refunds

IEEPA Tariff Refunds stem from a United States Court of International Trade ruling that found 2025 emergency tariff measures to be invalid. On March 4, 2026, the Court ordered U.S. Customs and Border Protection (CBP) to reliquidate affected entries and remove IEEPA duties, with trade law analysis suggesting that billions of dollars across thousands of entries could be subject to refund.

Exporters need clear guidance on eligibility, entry status, and documentation as the process develops. This article outlines eligibility, qualifying shipments, preparation steps, and what to do before the refund process is confirmed.

   

        

   

     

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IEEPA Tariff Refunds: Summary of What the Ruling Means for Australian Exporters

• The Court of International Trade ruled that tariffs imposed under the International Emergency Economic Powers Act during 2025 lacked legal authority and must be removed.
• IEEPA Tariff Refunds apply to 10% reciprocal tariffs introduced in April 2025, fentanyl-related surcharges, and certain country-specific duties imposed under emergency authority.
• Unliquidated entries are prioritised because they remain open within the customs system and can be corrected without formal legal action.
• Importers of Record must confirm whether they paid the duties directly or through a broker or logistics provider.
• CBP has not yet confirmed the official refund mechanism or portal, and no timeline has been issued for claims processing.
• Businesses can prepare now by reviewing entry summaries, setting up Automated Commercial Environment (ACE) accounts, and organising customs and financial records.

Explore practical options for managing US-bound freight through Couriers & Freight.

Which IEEPA Tariffs Apply and Whether Your Shipments Qualify

The Court of International Trade invalidated tariff actions introduced under emergency powers in 2025, directly affecting IEEPA Tariff Refunds eligibility. Affected measures include the 10% reciprocal tariff implemented in April 2025 under Executive Order 14257, fentanyl-related surcharges on certain trade flows, and additional country-specific IEEPA duty rates published in Federal Register notices.

Tariffs specific to China under Section 301 remain unchanged and fall outside this scope, as do Section 232 duties on steel, aluminium, and other covered products.

Unliquidated and recently liquidated entries

An unliquidated entry refers to a shipment where US Customs has not issued a final duty assessment. The Court of International Trade mandate instructed CBP to reliquidate these entries without applying IEEPA duties, making them the primary category for IEEPA Tariff Refunds. 

“Not yet final” means the duty calculation remains open to revision within the customs system. This category receives priority because corrections can be processed administratively. Exporters should confirm entry status through their customs broker or ACE Portal records.

Liquidated and final entries

Liquidated entries have completed the customs process, meaning CBP has issued a final duty determination. Eligibility for IEEPA Tariff Refunds in this category remains uncertain.

Current options include filing a formal protest or submitting a Post-Summary Correction, where applicable. 

However, CBP has not confirmed Post-Summary Correction as the official pathway for IEEPA-related refunds, and exporters should seek advice from a licensed customs broker before taking action.

How to Prepare Now Before the Refund Process Opens

Preparation plays a direct role in accessing IEEPA Tariff Refunds once CBP confirms the official process is in place. Exporters who organise documentation and systems early reduce delays and administrative errors.

1. Set up an ACE Portal account

The Automated Commercial Environment serves as the central system for U.S. Customs processing. CBP guidance indicates that refunds are now issued through the ACE Portal and linked ACH accounts following the removal of paper cheque refunds in February 2026.

Exporters must complete the official importer registration process to gain access and visibility over entry data.

2. Enrol ACH payment details

ACH enrollment allows CBP to transfer refunds directly into a nominated bank account. Businesses can either input their own banking details or designate a customs broker as the notified party to receive funds on their behalf, both of which are outlined in CBP guidance. 

Early enrolment ensures that IEEPA Tariff Refunds are not delayed once processing begins.

3. Understand the Post-Summary Correction process

A Post-Summary Correction allows importers to amend entry data after submission under defined conditions. 

While PSC is currently used within the customs system, CBP has not confirmed it as the official refund mechanism for IEEPA Tariff Refunds. Exporters should not submit corrections without professional advice, as incorrect filings may affect eligibility.

4. Review HTS classifications and tariff exposure

A review of Harmonised Tariff Schedule classifications helps exporters understand how duties applied to past shipments. With IEEPA tariffs removed and new Section 122 surcharges introduced, reviewing classification accuracy and tariff exposure is necessary to assess both refund eligibility and future cost impact. 

This review involves checking product codes, duty rates, and historical declarations with a licensed broker or freight provider.

Recent trade analysis indicates that billions of dollars in duties across thousands of entries may qualify for IEEPA Tariff Refunds, reinforcing the importance of early preparation.

Once CBP confirms the official mechanism, exporters may have three recovery pathways. 

• CBP is expected to clarify whether a centralised claims portal such as CAPE will be used, although this has not yet been confirmed. 
• Businesses may also file individual claims through the Court of International Trade, with legal costs commonly ranging from several thousand to tens of thousands of US dollars, depending on claim complexity. 
• A third option involves assigning the claim to a financial institution in exchange for partial upfront recovery. The appropriate approach depends on entry status, claim size, and professional advice.

Ship to the US with Couriers & Freight

The timeline for IEEPA Tariff Refunds remains unconfirmed, and compliance requirements for US-bound freight have shifted significantly over the past year. Exporters need visibility over shipment data, carrier options, and customs records to manage both historical exposure and future shipments.

Couriers & Freight provides access to multiple international carriers through a single booking platform, along with shipment tracking and customs clearance support for exports to the United States. Exporters can compare air freight to the United States carrier rates, book international courier services, and access entry documentation through one account.

Book your next US-bound shipment through Couriers & Freight's international shipping services. 

   

        

   

     

Book Air Freight or International Courier Services to the USA

     

Compare carrier rates and book US-bound freight through Couriers & Freight's international shipping platform.

     Get a Quote Now