IEEPA Tariff Refund Calculator

IEEPA Tariff Refund Calculator - International trade, tariff & customs attorneys. CBP defense. Call (818) 514-7680.

International Trade & Customs Law Services

Comprehensive customs and tariff defense for California importers at the Port of Los Angeles, Port of Long Beach, and all U.S. ports of entry. Services include CBP audit defense, tariff classification, customs valuation, Section 301/232/IEEPA tariff strategy, UFLPA forced labor compliance, duty drawback recovery, and Court of International Trade litigation.

Current Tariff Landscape

With effective tariff rates at historic highs, California businesses need experienced trade counsel. We handle Section 301 China tariffs, Section 232 steel/aluminum tariffs, IEEPA tariff refund claims, and reciprocal tariff compliance.

Free consultation for importers: (818) 514-7680.

Filed Court of International Trade Actions

Trembach Law Firm is not only admitted to the U.S. Court of International Trade — it has filed 3 complaints there. The actions are docketed at the Court of International Trade as 26-02506, 26-02846, 26-04095. Anatolii Trembach is admitted to practice before the Court of International Trade and is licensed in California, State Bar #349304, verifiable at apps.calbar.ca.gov.

This matters for IEEPA refunds specifically. The Court of International Trade has ordered CBP to reliquidate and refund on plaintiffs’ entries, and CBP’s CAPE Phase 3 for finally liquidated entries is likewise available only to importers who are plaintiffs at the Court. An importer who never filed has no confirmed, self-executing mechanism. Choosing counsel who has actually filed at that court, rather than counsel who only describes the process, is therefore a practical question and not a marketing one.

Jurisdiction over these actions rests on 28 U.S.C. § 1581, and the window to sue runs under 28 U.S.C. § 2636(i). No particular outcome is promised or guaranteed.

Fees, Costs and Case Results

Representation in these matters is offered on a contingency basis covering attorney fees only: there is no attorney fee unless we recover, and clients remain responsible for case costs, such as court filing and service fees. The specific terms that apply to a matter are set out in the written fee agreement for that matter.

Where this site refers to a verdict, settlement or court order, that result was dependent on the facts of that case, and results will differ if based on different facts. Past results do not predict or guarantee the outcome of any other matter, and no particular outcome is promised or guaranteed.

Frequently Asked Questions

How do I calculate my IEEPA tariff refund?
To calculate your IEEPA tariff refund: (1) Obtain entry summaries for all entries since February 2025; (2) Identify the HTS 9903.01 IEEPA duty lines on each entry; (3) Sum the IEEPA duty amounts across all entries; (4) Add estimated interest under 19 USC 1505. The IEEPA duty amount is the refundable principal. Interest accrues from the date of duty payment to the date of refund at the quarterly Treasury rate.
What is included in the refundable amount?
The refundable amount includes only the IEEPA tariff component of your total duty payment. This is the additional duty imposed under IEEPA Executive Orders—the 20%, 25%, 34%, 46%, or other rates depending on the country of origin and tariff program. Normal duties (Column 1 rates), Section 301 tariffs, Section 232 tariffs, Merchandise Processing Fees (MPF), and Harbor Maintenance Fees (HMF) are NOT refundable under the IEEPA ruling.
Are Merchandise Processing Fees (MPF) and Harbor Maintenance Fees (HMF) refundable?
No. MPF and HMF are assessed under separate statutory authority (19 USC 58c for MPF and 26 USC 4461 for HMF) and are not affected by the IEEPA ruling. These fees are based on the value of the imported goods and are not classified as tariffs or duties imposed under IEEPA. Only the IEEPA duty component of your total customs payment is refundable.
How is interest calculated on my refund?
Under 19 USC 1505, interest on duty refunds accrues from the date the duties were deposited with CBP to the date the refund is issued. The interest rate is the federal short-term rate set quarterly by the Treasury Department, which has been in the 4-5% range. Interest is calculated daily and compounded annually. For example, $100,000 in IEEPA duties paid in March 2025 and refunded in June 2026 (approximately 15 months) would accrue approximately $5,000-$6,250 in interest at a 4-5% annual rate.
What are the most common calculation errors?
Common errors include: (1) Confusing IEEPA duties with Section 301 tariffs on Chinese goods—these are separate programs; (2) Including MPF and HMF in the refund calculation; (3) Using the wrong IEEPA rate (e.g., using 34% for Chinese goods when the rate changed during 2025); (4) Failing to account for exclusions or exemptions that reduced the IEEPA rate on certain goods; (5) Double-counting entries that appear on multiple reports; and (6) Not accounting for entries where partial IEEPA rates applied.
Can I estimate my refund if I do not have detailed entry records?
You can make a rough estimate by reviewing your total customs duty payments since February 2025 and estimating the IEEPA percentage. For example, if you imported primarily from China at a combined IEEPA rate of 54%, and your total customs payments were $1,000,000, the IEEPA component might be approximately $540,000 out of the total (depending on other duty rates). However, an accurate calculation requires entry-level detail, so contact your customs broker for precise data.
When should I seek professional help with my refund calculation?
Professional help is recommended when: (1) You have entries from multiple countries with different IEEPA rates; (2) Your entries include goods subject to both IEEPA and Section 301 or Section 232 tariffs; (3) You have entries in Foreign Trade Zones or under special entry types; (4) Your total potential refund exceeds $50,000 and accuracy is critical for business planning; (5) You need to prepare litigation-ready calculations for CIT proceedings; or (6) You are unsure how to distinguish IEEPA duties from other duty types on your entry summaries.
What IEEPA rate applies to my goods from China?
Chinese goods were subject to multiple IEEPA rates during 2025: 20% fentanyl tariff (from February 4, 2025) plus the reciprocal tariff (which increased in stages). By April 9, 2025, the combined IEEPA rate on most Chinese goods was approximately 54% (20% fentanyl + 34% reciprocal). However, the rate varied by product category and time period, and some goods received temporary exclusions. Check the specific HTS 9903 annotations on your entries for the exact rate applied.
How do I handle entries with multiple IEEPA tariff layers?
Some entries may have multiple HTS 9903 IEEPA annotations reflecting different tariff programs (e.g., both fentanyl and reciprocal tariffs). Each IEEPA annotation represents a separate duty amount that is refundable. Sum all IEEPA duty amounts on each entry to get the total refundable amount per entry. Your customs broker can provide a breakdown showing each IEEPA duty layer separately.
What is a portfolio-level estimation and how does it work?
A portfolio-level estimation calculates the total potential refund across all your import entries rather than analyzing each entry individually. This approach uses aggregate data—total imports by country, average IEEPA rates, and total duty payments—to produce an overall refund estimate. Portfolio estimation is useful for initial business planning, budgeting, and determining whether the refund amount justifies the cost of pursuing the claim. A precise entry-by-entry calculation should follow for actual filing purposes.

Contact Trembach Law Firm

Trembach Law Firm, APC

27001 Agoura Road, Suite 350, Calabasas, CA 91301

Phone: (818) 514-7680

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