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 dealing with two simultaneous tariff events in July 2026. Looking backward: IEEPA duties paid between March 2025 and February 24, 2026 are refundable. The Supreme Court ruled those duties unlawful. 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 June 29, 2026, $71.06 billion has been certified and sent to Treasury, with statutory interest under 19 U.S.C. § 1505 adding approximately $650 million per month — typically 10–46% of the declared customs value on affected entries, depending on country of origin. Looking forward: Section 122 — the 10% global surcharge imposed as an IEEPA replacement — expires July 24, 2026. USTR has proposed Section 301 replacement duties at 12.5% on 46 countries, with a July 20, 2026 completion deadline. Pharma Section 232 takes effect July 31. Your landed cost model for Q3 2026 and beyond depends on how this transition plays out — and it requires immediate modeling.

IEEPA refund exposure is not uniform across your supply base. Recovery values depend on: (1) Country of origin — Vietnam-origin entries carried a 46% IEEPA rate, Taiwan 32%, China 20%, EU 20%, India 18%, South Korea 25%. 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 expires July 24, 2026 — 14 days from today. After that date, unless Congress extends it or replacement rates are in place, the 10% global surcharge disappears. USTR's proposed Section 301 duties at 12.5% on 46 countries have a July 20 completion deadline. Three scenarios matter for supply chain planning: Scenario 1 — Section 301 in place by July 24: Your landed costs shift from a flat 10% global rate to country-specific rates. Vietnam, Cambodia, and Thailand face some of the highest proposed Section 301 rates. Model by origin country, not globally. Scenario 2 — Section 122 lapses, no immediate replacement: Goods entering after July 24 avoid the 10% surcharge. If you have flexibility on entry timing, goods transiting now may benefit from delayed entry. Scenario 3 — Congressional extension: The 10% flat rate continues. No change needed. TariffIQ™ can model all three scenarios against your specific HTS codes and origin countries.

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.