IEEPA Refund Worked Examples: What Is Refunded and What Is Not

Four illustrative examples showing how much of a duty bill is IEEPA duty: a China entry with Section 301, an EU entry under the 15 percent all-in rule, a Canada entry, and a Section 232 line.

By the TariffClarity editorial team. Published September 24, 2026

Illustrations only. These examples use made-up companies and round numbers to show how the rules work. Real entries have more lines, exemptions, and dates. Your ACE ES-003 report shows the IEEPA duty actually paid.

Example 1: Chinese goods with Section 301

Entered June 2, 2025. Entered value $200,000. The product has a 3 percent ordinary duty and a 25 percent Section 301 duty.

DutyRateAmountRefunded?
Opioid-related IEEPA duty20%$40,000Yes
Reciprocal IEEPA duty10%$20,000Yes
Section 30125%$50,000No
Ordinary duty3%$6,000No
Total paid$116,000$60,000 refundable, plus interest

An importer expecting its whole $116,000 back would think the refund was short. It was not.

Example 2: EU goods under the 15 percent all-in rule

Entered September 15, 2025. Entered value $100,000. Ordinary duty 4 percent. From August 7, 2025, EU goods paid reciprocal duty only up to a 15 percent total.

DutyRateAmountRefunded?
Reciprocal IEEPA duty (15% minus 4%)11%$11,000Yes
Ordinary duty4%$4,000No

The same product entered in June 2025 would have paid 10 percent reciprocal duty on top of the 4 percent.

Example 3: Canadian goods and USMCA

Entered March 5, 2025. Entered value $80,000. The goods qualified for USMCA, but the exemption did not start until March 7, 2025.

DutyRateAmountRefunded?
IEEPA duty on Canadian goods25%$20,000Yes

The same goods entered on March 7, 2025 or later with USMCA claimed paid no IEEPA duty, so there is nothing to refund.

Example 4: A Section 232 line in the same entry

An entry of auto parts from Japan in October 2025 has two lines. Line 1, $50,000, is covered by the Section 232 auto parts duty. Line 2, $30,000, is not, and has a 2.5 percent ordinary duty.

LineDutyAmountRefunded?
Line 1Section 232 (no reciprocal duty on this line)Section 232 amountNo
Line 2Reciprocal IEEPA duty (15% minus 2.5%)$3,750Yes

Only line 2 carries IEEPA duty. An estimate based on the whole entry value would overstate the refund.

Interest

Refunds generally include interest under 19 CFR 24.36, calculated from the date of payment at rates set quarterly. The examples above do not include interest.

What this means for importers

Separate IEEPA lines from everything else before comparing a refund to what you paid. Try the refund estimator for a rough number, then confirm with your ES-003 report.

General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.

Sources

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General information, not legal advice. Tariff refund rules and court rulings are changing. Deadlines depend on your own entries. Confirm your options with a licensed customs broker or attorney. TariffClarity is not a law firm or customs broker.

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