By Tuesday evening February 24, 2026, CBP had officially halted IEEPA duty collection and Treasury had confirmed the scale of what’s owed back. The working estimate across Treasury, CBP and the Peterson Institute is USD 175 billion in refundable IEEPA duties collected since February 4, 2025. Roughly 330,000 active importer of record numbers were exposed. For chemical and raw material importers specifically, the exposure is concentrated and large, because your entries were typically high value, high duty, and filed monthly over the full 12 months plus of the IEEPA regime.
If you paid the 10% fentanyl tariff plus the 10% reciprocal tariff on a single 20 foot container of Chinese polymer feedstock valued at USD 180,000 CIF, you paid USD 36,000 in IEEPA duties on that container. Twelve months of monthly containers puts USD 432,000 of refundable duty on one SKU on one lane. If you run a typical mid sized chemical distributor with five to eight active Chinese suppliers, your refund inventory is comfortably in the seven figures and quite possibly the eight. The claim will not file itself, and the process CBP set out in Monday’s Federal Register notice has specific deadlines that have already started running.
This piece walks you through which bucket your entries fall into, the paperwork CBP wants, a refund calculation by HS code you can copy, and the three common mistakes that will cost importers real money in the next 60 days.
Three buckets, three procedures
Every entry you filed paying IEEPA falls into one of three procedural buckets. Your refund pathway depends entirely on which bucket the entry sits in.
Bucket one is unliquidated entries. Under 19 USC 1500 and 19 CFR 159, CBP normally liquidates an entry within 314 days of filing. The agency suspended liquidation on all IEEPA flagged entries on February 24, which means thousands of your 2025 and early 2026 entries are still open. These are the easiest to refund because CBP can simply reliquidate them at the correct duty rate and issue the refund automatically once the electronic refund system is stood up. The Federal Register notice sets a target go live date of August 22, 2026.
Bucket two is liquidated entries still within the 180 day protest window under 19 USC 1514. If your entry liquidated on say September 15, 2025, you have until mid March 2026 to file a protest. Miss that window and you drop to bucket three.
Bucket three is liquidated entries outside the 180 day protest window. These are not lost. Under 19 USC 1520(d), CBP can reliquidate on request when there is a clerical error, mistake of fact or other inadvertence. The SCOTUS Learning Resources ruling triggered a Court of International Trade order on February 23 directing CBP to treat the IEEPA classification as a reliquidation eligible error, which opens the 1520(d) pathway. You get one year from liquidation to file. That protects your entries going back to February 24, 2025, but not further back. Entries from February 4 through February 23, 2025 require a CIT action filed directly under 28 USC 1581(i), which is a court proceeding, not an administrative claim.
The paperwork CBP wants
For each entry you are claiming against, CBP will want four documents. Your entry summary CBP Form 7501 with the Chapter 99 codes 9903.01.20 and 9903.01.24 shown on the line level. The commercial invoice matching the entry. The bill of lading with CIF value substantiated. And proof of duty payment, which is the ACH debit or single transaction bond record.
If your broker handled the entry, all four of these exist in ACE and can be exported in bulk. If you file through multiple brokers, you will need to consolidate. Start that consolidation now because the single biggest choke point in the refund process over the next six months will be importers who cannot produce clean 7501s because they changed brokers mid year.
CBP will also want a single refund claim cover sheet per importer of record, which is the new Form 29R, published Monday. Form 29R asks for importer number, total dollar refund claimed, total number of entries, and a certification that the claim is not duplicative of a separate protest or CIT filing. The 29R is the keystone document. File it wrong and the whole claim sits in queue.
Refund calculation by HS code, worked example
Here is a refund calculation across five chemical HS codes an industrial importer would typically run. The math uses 10% fentanyl plus 10% reciprocal, which was the full 20 points of IEEPA duty stacked on top of Section 301 and base MFN. Entry values are 12 months of shipments, February 2025 to January 2026 inclusive.
| HS code | Description | Annual entry value USD | IEEPA rate | Refund owed |
|---|---|---|---|---|
| 2917.36.00 | Terephthalic acid and salts | 4,176,000 | 20.0% | 835,200 |
| 3904.10.00 | Polyvinyl chloride primary forms | 2,880,000 | 20.0% | 576,000 |
| 3208.10.00 | Polyester coatings in solvent | 1,620,000 | 20.0% | 324,000 |
| 2903.39.20 | Fluorinated derivatives | 960,000 | 20.0% | 192,000 |
| 3204.17.60 | Pigment preparations | 744,000 | 20.0% | 148,800 |
| Total | 10,380,000 | 2,076,000 |
USD 2.076 million is owed back on a USD 10.38 million chemical import book. That is a real balance sheet event for a distributor with USD 40 million in revenue. Do not plan to spend it. CBP is not going to issue checks in Q2 2026. The working assumption for cash receipt on bucket one entries is Q4 2026 to Q1 2027. Bucket two and three claims will stretch into 2028.
Court of International Trade versus administrative claim
For most of your entries the CBP administrative refund will be faster and cheaper than a CIT action. You do not need a lawyer to file a 29R. Your broker can do it under your customs power of attorney.
Where you do need a trade counsel is the pre February 24, 2025 entries, meaning the handful of entries filed in the first 20 days of the IEEPA regime, and any entry where CBP denies your administrative claim. In those cases you file under 28 USC 1581(a) for denial of protest, or 28 USC 1581(i) for entries outside the administrative pathway. CIT filing fee is USD 350, and a competent trade firm will run a batched IEEPA refund case for a flat fee around USD 8,000 to USD 15,000 per importer. Do not pay a percentage of your refund. That market is already full of firms quoting 15 to 25% contingency on claims that your broker can file for zero marginal cost.
The three mistakes that will cost you
First, do not dual track. If your broker files a 29R administrative claim and your lawyer files a 1581(a) CIT action on the same entry, CBP will suspend both and you wait 18 months to resolve the conflict. Pick one pathway per entry and document your choice.
Second, do not forget to claim Merchandise Processing Fee and Harbour Maintenance Fee overcollection. The MPF cap under 19 CFR 24.23 is USD 614.35 per entry as of the 2025 adjustment. If your commercial invoice value included the IEEPA duty in a landed cost formula used for MPF, you may be owed a secondary MPF refund. This is small per entry but meaningful at scale. On the 2,076,000 refund above, the secondary MPF claim is roughly USD 14,000.
Third, do not let the 180 day protest clock run on bucket two entries while you wait for the CBP electronic system. CBP does not want you to file protests because they intend for the electronic system to absorb most claims. But if your entry liquidated in August 2025, your window closes in February 2026. Filing a timely protest preserves your claim even if CBP later folds it into the electronic refund process.
A week one action plan
Pull every 7501 with Chapter 99 code 9903.01.20 or 9903.01.24 from ACE. Export to spreadsheet. Sort into three buckets. Calendar the 180 day protest deadline against every bucket two entry. File a placeholder protest on any entry where the deadline falls before May 2026. Submit Form 29R for your bucket one entries on March 15 when CBP opens the intake window. Retain trade counsel only for the pre February 24, 2025 entries and any CIT escalation.
Reconcile your general ledger. Most chemical distributors expensed IEEPA duty through cost of goods sold, which means the refund will land as a 2026 COGS recovery and flow through to EBITDA. Talk to your auditor now about whether you need to restate 2025 inventory carrying values. PwC and Deloitte have both published guidance in the 48 hours since the ruling and the treatment is not obvious.
What the USD 175 billion means for the next tariff fight
USD 175 billion is about 0.6% of annual US GDP. It is a meaningful macro event, but it is also a political event. Congress will be asked in the next 60 days to pass a durable tariff authority to replace IEEPA. Importers who get their refund claims filed cleanly in Q2 2026 will be sitting on cash when that Congressional debate concludes. Importers who stall will be at the back of a queue that will run for years.
The refund is not a gift. It is a return of money CBP should not have collected. Treat it like you would treat a tax refund. File on time, file clean, do not pay someone 20% to file what your broker can file for zero. And reprice your 2026 customer contracts on the assumption that the 20 point windfall goes to your customers over six to 12 months as pricing resets. The importers who hold the margin the longest are the ones who communicated clearly with their customers in week one.