Frequently Asked Questions

Everything you need to know about IEEPA tariff refunds and how CustomsGenius can help.

Last updated: March 4, 2026

General / Product

What is CustomsGenius?

CustomsGenius is a B2B SaaS platform built by eCompliance, Inc. that automates IEEPA tariff refund recovery for U.S. importers and customs brokers. It ingests customs entry data, identifies refund-eligible entries, calculates recovery amounts, and triages the highest-priority claims.

Who is CustomsGenius built for?

U.S. importers of record, licensed customs brokers, trade compliance teams, and freight forwarders who need to identify and recover overpaid IEEPA duties across large entry portfolios.

What data does CustomsGenius need to get started?

The platform works with CF-7501 entry summaries, ACE exports, broker ERP data, or commercial invoices. Most users can get started by exporting their entry data from ACE or their broker's system.

Is CustomsGenius a law firm or customs broker?

No. CustomsGenius is a technology platform. It does not provide legal advice, file entries on your behalf as a broker, or represent you in court. It is a tool that helps you and your broker or counsel identify, quantify, and prioritize IEEPA refund claims.

How does CustomsGenius prevent errors in refund calculations?

The platform cross-references HTS classifications, duty rates, country of origin, and entry dates against the specific IEEPA executive orders and their effective date ranges. Flagged entries are surfaced with the underlying data so your team or broker can verify before filing.

Can I switch plans at any time?

Yes. You can upgrade or downgrade your plan at any time. Changes take effect at the start of your next billing cycle.

What document formats does CustomsGenius support?

CustomsGenius processes PDFs, scanned images, and electronic entry summaries (7501s). Commercial invoices and bills of lading are automatically matched against your 7501 entry summaries. Our OCR engine handles even low-quality scans, and we support bulk uploads of hundreds of documents at once.

IEEPA Tariffs & Refunds

What are IEEPA tariffs?

IEEPA tariffs were additional ad valorem duties imposed by President Trump beginning in early 2025 under the International Emergency Economic Powers Act. They applied broadly to imports from China, Canada, Mexico, and most other trading partners under various executive orders (EO 14193, 14194, 14195, 14257, and others). On February 20, 2026, the U.S. Supreme Court ruled 6-3 that the president lacked authority to impose tariffs under IEEPA.

How much was collected in IEEPA tariffs?

The U.S. government collected an estimated $175 billion in IEEPA tariffs between early 2025 and the Supreme Court's February 2026 ruling.

Are IEEPA tariffs being refunded automatically?

No. CBP is not automatically refunding IEEPA duties. Importers must affirmatively file for refunds as determined by the U.S. Court of International Trade.

Update (March 4, 2026): The CIT issued a universal order in Atmus Filtration, Inc. v. United States directing CBP to liquidate all unliquidated entries without IEEPA duties and reliquidate all liquidated-but-not-final entries without IEEPA duties. This effectively mandates refunds for entries that have not become final.

How do I know if my imports qualify for an IEEPA refund?

If you imported goods assessed additional duties under any IEEPA executive order between early 2025 and February 20, 2026, those entries may be eligible. Eligibility depends on country of origin, HTS classification, entry date, and whether any exclusions applied. CustomsGenius automates this analysis across your full entry portfolio.

What is the difference between unliquidated and liquidated entries?

Liquidation is CBP's final determination of duties owed on an entry. CBP typically liquidates entries within 314 days of the date of entry. Unliquidated entries are still open and can be corrected via Post-Summary Correction (PSC). Liquidated entries require a formal protest under 19 U.S.C. § 1514 or court action to recover overpaid duties.

Update (March 4, 2026): The CIT's universal order in Atmus Filtration treats these categories differently. Unliquidated entries will be liquidated without IEEPA duties (automatic refund). Liquidated-but-not-final entries (protest window still open) will be reliquidated without IEEPA duties. Entries that are both liquidated and final are outside the scope of the CIT order.

What is the deadline to file for IEEPA refunds?

Most likely, importers must file protests within 180 days of liquidation. As of March 2026, the IEEPA refund mechanism is currently being decided by the U.S. Court of International Trade, so this question will be given a concrete answer when the court clarifies the deadline.

Update (March 4, 2026): The CIT's universal order in Atmus Filtration covers unliquidated and liquidated-not-final entries directly. Entries that have already become final (liquidated with protest deadline expired) remain outside the CIT order's direct reach and may require separate action.

How long does it take to receive a refund from CBP?

Processing times depend on the filing method and CBP's workload. Because of the size of the IEEPA refunds, this process will likely take longer than its usual 6–8 week timeframe. CBP issues all refunds via ACH.

Do I need to file a lawsuit to get my IEEPA refund?

Not necessarily. While nearly 2,000 importers have filed protective actions at the CIT, the Court of International Trade has not yet established the filing requirements for importers. Because of the profit incentive, law firms tend to be unreliable sources for assessing the actual need to file lawsuits.

Update (March 4, 2026): The CIT's universal order in Atmus Filtration may reduce the need for individual lawsuits for entries covered by the order (unliquidated and liquidated-not-final entries). Importers with entries that have already become final may still need separate legal action.

What is a protective action at the Court of International Trade?

A protective action is a lawsuit filed at the CIT under 28 U.S.C. § 1581(i) to preserve an importer's right to a refund. Many importers filed these in late 2025 to ensure that even if CBP liquidated their entries, their claims would remain viable. The CIT stayed these cases pending the Supreme Court decision and is now expected to establish a case management process.

Update (March 4, 2026): With the CIT's universal order in Atmus Filtration directing CBP to liquidate and reliquidate entries without IEEPA duties, the practical necessity of individual protective actions is reduced for entries covered by the order.

Does filing a PSC guarantee a refund?

No. A Post-Summary Correction (PSC) is a request to amend an entry. CBP must accept the correction. If CBP denies the PSC, the importer can file a protest. If the protest is also denied, the importer can challenge the denial at the CIT.

What documentation do I need for an IEEPA refund claim?

At minimum: CF-7501 entry summaries, commercial invoices, proof of IEEPA duties paid, and entry-level detail showing HTS classifications and country of origin. An ACE report of duties paid and liquidation dates is also recommended. CustomsGenius consolidates this documentation automatically and flags any missing evidence.

Are Section 301 or Section 232 duties also refundable under this ruling?

No. The Supreme Court's February 2026 ruling applied specifically to tariffs imposed under IEEPA. Section 301 duties (Trade Act of 1974) and Section 232 duties (Trade Expansion Act of 1962) were imposed under different statutory authority and remain in effect.

Do I need to be enrolled in ACH to receive a refund?

Yes. CBP processes all duty refunds electronically through the Automated Clearing House (ACH). If you are not enrolled, you will not receive refunds.

Who is the importer of record and why does it matter?

The importer of record (IOR) is the party legally responsible for ensuring imported goods comply with U.S. customs requirements. The IOR is the entity eligible to receive duty refunds from CBP. In some informal entry or express consignment scenarios, an intermediary may be listed as the IOR, which can complicate claims.

Can my customs broker file for IEEPA refunds on my behalf?

Your broker can file PSCs and protests as your authorized agent. However, the refund is paid to the importer of record. Working closely with your broker is critical to ensuring filings are timely and documentation is complete.

What happens if my entries liquidate before I file?

Once an entry liquidates, you can no longer file a PSC. You must file a protest within 180 days of the liquidation date under 19 U.S.C. § 1514. If denied, you can challenge at the CIT. Entries are liquidating on a rolling basis, so missing the window limits your options.

What IEEPA executive orders were involved?

The primary IEEPA tariff executive orders were: EO 14193 (Canada), EO 14194 (Mexico), EO 14195 (China/Hong Kong), and EO 14257 (reciprocal tariffs on most other countries). Each had different effective dates, duty rates, and exclusion provisions. See our IEEPA tariff codes page for a complete breakdown.

Were goods in transit when IEEPA tariffs took effect subject to the duties?

If merchandise was entered for immediate transportation under 19 CFR 141.69(b) prior to the IEEPA implementation date, it was not subject to the additional duty. Goods entered after the effective date were subject to the tariffs regardless of when they shipped.

Can I earn interest on my IEEPA refund?

For liquidated entries where duties were overpaid, statutory interest may apply from the date of deposit. Interest rates are tied to Treasury rates and change quarterly. However, interest is generally not payable on unliquidated entries corrected via PSC before liquidation, since no overpayment is finalized.

Still have questions?

Get in touch and we'll walk you through everything.

Contact us

Request Beta Access

Get early access to CustomsGenius and start recovering IEEPA refunds faster.

Beta Pilot Ongoing