Supply Chain Managers: Recover IEEPA Tariffs and Remodel Your Landed Costs

The Supreme Court’s ruling in Learning Resources v. Trump opened $166 billion in IEEPA refunds for 330,000+ importers. Supply chain managers are managing two distinct IEEPA workstreams. Looking backward: IEEPA duties paid between March 2025 and the Supreme Court's ruling are refundable. The Court held those duties unlawful, and CBP is processing refunds through CAPE. For supply chain teams with significant China, Vietnam, Taiwan, or Southeast Asia sourcing, the aggregate IEEPA duty payments represent a material cash recovery opportunity. As of CBP's August 21, 2026 data (filed August 25, 2026), $132.5 billion has been accepted for CAPE processing and $106.6 billion has been sent to Treasury for disbursement, with statutory interest continuing to accrue under 19 U.S.C. § 1505 on unpaid balances — refund rates on affected entries typically ran 10–30% of declared customs value, depending on country of origin. Looking forward: Section 122 — the 10% global IEEPA surcharge — expired on schedule at 12:01 AM EDT on July 24, 2026, its 150-day statutory limit. USTR replaced it the same day with new Section 301 forced-labor tariffs of 10% or 12.5%, now applied across roughly 60 economies representing about 99.4% of U.S. imports. Your landed cost model should be built on this current structure, not the surcharge it replaced.

IEEPA refund exposure is not uniform across your supply base. Recovery values depend on: (1) Country of origin — sustained IEEPA rates settled well below the levels first announced: China up to 30% (10% reciprocal plus a fentanyl-related surcharge, reduced to 10% in November 2025), Vietnam 20%, Taiwan 20%, the EU 10–15%, India 18% (reduced from 25% under the U.S.–India interim trade agreement effective February 2026), and South Korea 15%. A mixed supply base requires entry-by-entry analysis. (2) Entry liquidation status — unliquidated entries and entries within 80 days are Phase 1-eligible. Reconciliation-flagged entries without a Type 09 are Phase 2-eligible. Finally liquidated entries require a CIT case for Phase 3. (3) HTS classification — IEEPA Chapter 99 codes vary by country at the eight-digit level. Entries without the correct Chapter 99 code fail CAPE validation. (4) Entry value — high-value entries generate proportionally higher refunds. Prioritize your highest-value, highest-IEEPA-rate entries for Phase 1 and Phase 2 filing. TariffIQ™ maps your entire import portfolio against these variables to identify your maximum recoverable position.

Section 122's flat 10% global IEEPA surcharge expired on schedule at 12:01 AM EDT on July 24, 2026, having hit its 150-day statutory limit. USTR did not leave a gap: that same day, new Section 301 forced-labor tariffs took effect at 10% or 12.5%, applied across roughly 60 economies covering about 99.4% of U.S. imports. For supply chain planning, the practical shift is from a flat, uniform global rate to a country-specific rate structure — which means landed cost models built globally are now the wrong tool. Origin country decides the rate that applies to a given entry, so sourcing and routing decisions should be modeled origin-by-origin rather than against a single blended surcharge. Entries that transited or entered before July 24 were still subject to the Section 122 surcharge; entries after that date fall under the current Section 301 structure. Supply chain teams that haven't yet rebuilt their landed cost model around country-specific rates are likely carrying stale assumptions into sourcing, quoting, and inventory decisions today. TariffIQ™ can model your current landed costs against your specific HTS codes and origin countries under the structure now in effect.

Your customs broker is the party who filed your original entry summaries in ACE and who must submit your CAPE Declarations. The challenge: customs brokers are managing CAPE filings for every client simultaneously, creating capacity constraints during the peak Phase 2 and Phase 3 filing windows. Supply chain managers can accelerate their refund by providing brokers with a pre-validated entry package — the exact work TariffIQ™ performs. We identify your eligible entries, validate HTS codes, check ACH enrollment, sequence the Type 09 filing order, and deliver a ready-to-file CAPE Declaration CSV. Your broker uploads it to ACE. The division of labor is clean: we handle the analysis and prep; your broker handles the regulated filing. This reduces broker time-per-entry and moves your filings to the front of the queue.