The Tariff Refund Playbook
A Retailer’s Guide to Who Qualifies, What Changed, and How to Turn It Into Leverage
The Supreme Court struck down the IEEPA tariffs. A federal refund portal is now open. Up to $175 billion could be returned to importers across the country. Most independent retailers will not be the ones collecting that money. But that does not mean you walk away empty handed. Here is everything you need to know, and exactly what to do next.
- 1.The Background: What Happened
- 2.Who Actually Qualifies for a Refund
- 3.If You Are Not an Importer of Record: Your Vendor Playbook
- 4.Concessions Worth Asking For
- 5.The Bigger Picture
- 6.If You Are an Importer of Record: How to File
Let us be direct: the majority of independent retailers in the U.S. buy merchandise through domestic wholesalers and distributors. That means most of you did not pay tariffs directly to the U.S. government. Your vendors did. And your vendors are now positioned to receive those tariff dollars back.
You, however, paid higher wholesale prices because of those tariffs. That is a real cost. And it creates a real opening. This guide will walk you through both sides of the story so you can act with clarity and confidence.
The Background: What Happened
In February 2026, the U.S. Supreme Court ruled 6 to 3 that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were illegal. The ruling invalidated both the tariffs on Canada, Mexico, and China as well as the broader reciprocal tariffs that had been imposed globally starting in April 2025. CBP stopped collecting IEEPA tariffs on February 24, 2026.
The scale of what was collected during that period is staggering. More than 330,000 U.S. importers paid approximately $166 billion in IEEPA duties across more than 53 million shipments between April 2025 and February 2026. The refund process that has now been launched represents the largest customs refund operation in U.S. history.
Not All Tariffs Are Being Refunded
Only IEEPA tariffs are covered by this refund process. Section 232 tariffs on steel, aluminum, autos, copper, and semiconductors remain in force and are not eligible for refund. The 10% global Section 122 surcharge that replaced IEEPA on February 24, 2026 is also a separate legal authority and is not part of this process. If your vendors are still quoting elevated prices on goods covered by Section 232, those are separate tariffs with no current refund pathway.
Who Actually Qualifies for a Refund
This is the most important distinction in this entire guide. Read it carefully, because misunderstanding it will send you in the wrong direction.
Only the importer of record is entitled to a tariff refund. That is the business that paid IEEPA duties directly to U.S. Customs and Border Protection when goods crossed the border. If your vendor or wholesaler was the importer of record, the refund belongs to them, not to you.
Two types of parties can file claims: the importer of record themselves, or a licensed customs broker who filed entries on the importer's behalf. Consumers who paid higher retail prices are not eligible. Retailers who purchased from domestic distributors are not eligible. The refund flows to whoever wrote the check to Customs.
For most independent specialty retailers, the path to benefit runs through your vendor relationships, not through a direct filing. We cover exactly how to approach that in Sections 3 and 4. But first, for those retailers who do import directly, we have included a complete filing guide at the end of this playbook in Section 6.
If You Are Not an Importer of Record: Your Vendor Playbook
For the majority of independent retailers, the tariff refund story is not about filing a claim. It is about understanding that your vendors are about to receive significant money back on duties that caused them to raise their wholesale prices on goods you already bought and sold.
Think about what happened: your vendor raised their prices to cover tariff costs. You paid those higher costs. Your margin took the hit. Now those tariff costs are being refunded. The money does not automatically flow back to you. But you have every right to have a direct conversation about it.
Do not wait for your vendors to bring this up. They likely will not. You need to initiate this conversation, and you need to do it with specific numbers and specific asks.
Before you pick up the phone or send an email, do your homework. Know how much you ordered from that vendor during the period when tariff surcharges were in effect. Know the dollar amount of any price increases you absorbed. Know your current inventory levels on their product. Vendors respond to specificity. Walking in with data is walking in with leverage.
Concessions Worth Asking For
Go into this conversation with a prepared list of specific asks. Vague requests produce vague results. Here are five concessions that are reasonable, precedented, and directly tied to the tariff situation.
Extra Discounts on Future Orders
Ask for a temporary additional discount applied at the invoice level on your next one to three seasonal buys. Even a 3% to 5% reduction on forward orders meaningfully improves your initial markup and gives your open to buy plan more room to work with. Frame this as a direct offset for the elevated cost you carried during the tariff period.
In Season Fill In Opportunities With an Extra Discount
Request access to in season fill in inventory at a reduced cost, perhaps 10% to 15% below regular fill in pricing. This lets you chase what is working without paying full price on replenishment, protecting your sell through rate and your margin at the same time. Vendors benefit too because fill in orders help clear their warehouse positions.
Extended Dating or Improved Payment Terms
Ask for net 60 or net 90 terms on upcoming orders, or for dating that extends past the season break. Better payment terms are a direct cash flow improvement that lets you carry the right inventory without straining your working capital. This is often easier for vendors to say yes to than a straight price reduction.
Extra Co-op Marketing Funds
Request an increase in your co-op advertising allowance above your standard contractual rate. Ask for an additional 1% to 3% on your forward buys to be applied as co-op dollars. This gives you ammunition to drive traffic and sell through while your vendor benefits from increased brand visibility and volume. It is a win on both sides when positioned correctly.
Expanded Return Privileges on Slow Sellers
If you took in product at elevated tariff driven cost and it did not move at the margins you needed, ask for expanded return authorization. This is especially relevant for items that were priced higher than your market could bear, making them difficult to clear at retail without eroding your margin further.
You Are Not Asking for a Favor
Go into these conversations knowing that you are not asking for charity. Your vendor raised their prices because of a tariff that has now been ruled illegal, and they are receiving a refund on those exact duties. A portion of that refund was funded by the higher prices you paid. Framing the conversation this way, professionally and with facts, gives you a foundation that is fair and difficult to push back against.
The Bigger Picture for Your Business
This moment matters beyond the immediate conversation. The tariff environment of the past year exposed how quickly your cost of goods can shift based on decisions made far above the store level. Independent retailers who navigated it best did so because they had tight inventory discipline and strong vendor relationships built on mutual respect and clear communication.
If your margins took a hit during this period, the window to rebuild them through vendor negotiations is open right now. Use forward order discounts to shore up your initial markup. Use better payment terms to protect your cash flow. Use co-op increases to fund the marketing investment you need to drive sell through.
The retailers who recover fastest will be the ones who treat this as an active opportunity rather than a passive news story. The refunds are happening. The question is whether that money trickles back to you, or whether it stays in your vendor's pocket.
Want Help Building the Strategy?
The Management One team works with independent retailers every day to build inventory plans, vendor strategies, and margin structures grounded in real data. If you want support preparing for these vendor conversations, understanding what your margin plan should look like going forward, or simply making sense of the current trade environment, we are ready to help.
Talk to a Retail AdvisorIf You Are an Importer of Record: How to File
If your business imported goods directly from overseas manufacturers and you were listed as the importer of record on your customs entries, you may be owed a significant refund. This applies to retailers who bring in private label product, who buy direct from factories in full container loads, or who source internationally through their own import operations.
The refund process runs entirely through a new federal portal called CAPE, which operates within the existing ACE (Automated Commercial Environment) system used by importers and customs brokers. CAPE became available on April 20, 2026, and it is now the exclusive mechanism for filing IEEPA refund claims.
Where to Start: The CBP IEEPA Refund Page
The official information page, including how to apply for an ACE account, how to set up ACH banking for electronic refunds, and the mechanics of filing a CAPE Declaration, is maintained by U.S. Customs and Border Protection at:
https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds
CBP updates this page regularly as new phases and guidance are released
The Step by Step Filing Process
Here is what you need to do to file a claim. Work with your customs broker if you have one, as they can file on your behalf and may already be preparing your entries.
Not Every Entry Qualifies in Phase 1
CAPE is being rolled out in phases. Phase 1 covers unliquidated entries and entries liquidated within the past 80 days, which represents roughly 63% of all IEEPA duties paid. Entries that were fully liquidated beyond that window, entries tied to drawback claims or protest proceedings, and certain warehouse entries are excluded from Phase 1 and will be addressed in future phases. CBP has not yet announced Phase 2 timing, but industry experts expect the rollout to continue through late 2026. Preserve all documentation on your excluded entries and watch the CBP page for Phase 2 guidance.
If you need cash now and do not want to wait 60 to 90 days, some financial firms and trade logistics companies are purchasing tariff refund claims outright. You receive immediate payment and they handle the administrative filing. This is worth exploring if cash flow is a priority, though you will receive less than the full refund value.
About the Author
Mike Baranov
Mike Baranov is a member of the Leadership Team at Management One, bringing 25 years of hands-on retail experience to the work of helping independent retailers build stronger, more profitable businesses. His career has spanned the full breadth of retail leadership, including roles as Chief Executive Officer, General Merchandise Manager, and E-Commerce Director. That range gives Mike a rare ability to see retail challenges from every angle, from the sales floor to the boardroom, and to translate complex industry shifts into clear, actionable strategy for the retailers he works with.