Did You Overpay on 2025
Emergency Tariffs?

What Are IEEPA Tariffs?

In February 2025, President Trump invoked the International Emergency Economic Powers Act (IEEPA) to declare a national emergency over trade deficits and border security, imposing sweeping emergency tariffs on imports from Canada, Mexico, and China. These tariffs are separate from — and stack on top of — existing Section 301, Section 232, and most-favored-nation (MFN) rates.

Unlike traditional tariff increases that go through Congress or the standard trade remedy process, IEEPA tariffs can be imposed quickly by executive order and can be modified or removed just as rapidly, creating significant uncertainty for importers who have already paid duties.

IEEPA Tariff Timeline

Who Can Claim IEEPA Tariff Refunds?

Not every importer is entitled to a refund, but a significant number of overpayments have occurred due to the rapid rollout of these emergency tariffs. You may be eligible if:

• Your goods entered the US before the IEEPA effective date (February 4, 2025 for Canada/Mexico; relevant escalation date for China) but were assessed tariffs retroactively
• Your goods from Canada or Mexico were USMCA-compliant — USMCA-eligible goods are explicitly exempt from the IEEPA tariffs, but some entry filers assessed the tariff incorrectly
• Your goods fall into an explicitly exempt product category under the relevant IEEPA executive order (e.g., Canadian energy imports only face 10%, not 25%)
• Your goods were in-transit or entered under bond before the effective date and later assessed the tariff upon liquidation
• You paid the tariff but your goods qualify for a first sale valuation that reduces the dutiable value (and thus the tariff amount)
• A CBP classification error resulted in your goods being assessed at the wrong HTS code, triggering an IEEPA tariff that wouldn't apply to the correct classification
• You imported goods that were substantially transformed in Canada or Mexico from third-country inputs, and the finished goods qualify as originating under USMCA rules of origin

How to File a CBP Protest for IEEPA Tariff Refunds

To recover overpaid IEEPA tariffs, importers must file a formal protest with US Customs and Border Protection (CBP) using Customs Form 19 (CF-19). This is a legal challenge to CBP's tariff assessment and must meet specific requirements:

• File within 180 days of liquidation — do not miss this deadline, as it is strictly enforced
• Include the entry number, port of entry, liquidation date, and specific legal basis for the protest (cite the relevant IEEPA executive order sections and exemptions)
• Attach supporting documentation: USMCA Certificate of Origin (if applicable), commercial invoices, bills of lading, and any product classification rulings
• Submit through ACE (Automated Commercial Environment) or via paper to the appropriate CBP port director
• For USMCA claims, ensure you have a valid Certificate of Origin covering the entry date — retroactive certificates may not be accepted