Who's Ready to Process $170 Billion in Tariff Refunds? (Hint: Not Humans.)

Update (April 9, 2026): Since this article was published, CBP has announced its CAPE refund portal opening April 20, 2026. For current filing guidance, CAPE Phase 1 eligibility, documentation requirements, and next steps, see our updated IEEPA Tariff Recovery Guide.

I still remember when I realized tariffs were coming back. It was early 2017 in Washington and I was in a meeting with U.S. Commerce Secretary Wilbur Ross and my boss, the leader of Canada’s opposition. I listened as he explained the new administration’s plans to reverse decades of American trade policy.

But I doubt even Mr. Ross imagined the scale of the tariffs we’ve seen over the past year — let alone what would happen if the government suddenly had to give the money back.

Yesterday, the Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs — striking down a large share of the import duties collected over the past year. That puts an estimated $170 billion in collected duties in play — money paid by over 301,000 importers across 34 million customs entries.

The administrative task ahead is enormous. If there were ever a moment for AI agents to prove they’re ready for the real world, this is it.

The refund nobody planned for

The Court’s IEEPA ruling struck down the tariffs, but didn’t order refunds. That will play out through CBP processes and refund litigation in the Court of International Trade.

So companies know they’re owed money. But they don’t know how much, how to get it, or whether they’ll need to fight for it.

Roughly 19 million entries haven’t been finalized and can still be corrected. The other 15 million are locked in, requiring formal protests or litigation.

Both pathways demand documentation most companies haven’t organized: entry summaries, proof of payment, classification records, and filing deadlines that vary by entry.

There aren’t enough people to do this

Here’s the part that should concern every CFO and supply chain leader: the universe of trade compliance professionals is small. Customs brokers are stretched thin on day-to-day compliance. The trade bar is capable but expensive. And most companies’ internal compliance function is one or two people managing spreadsheets.

That’s fine for normal operations. It is not fine for reconciling thousands of entries across multiple brokers, tracking rolling deadlines, and filing corrections in a system designed for individual transactions — not mass recovery.

Capacity is going to be the thing standing between companies and their money.

AI agents have been waiting for this moment

The work of recovering tariff refunds — matching entry records against payment data, determining recovery pathways — is repetitive, document-intensive, and high-volume. It’s exactly the kind of work that AI is better than humans at.

Our clients are already using our agents for regular tariff and freight invoice audits. The agents take unstructured entry forms and broker invoices, audit them against official customs sources, flag overpayments, and can bring disputes to their brokers — autonomously, at scale. They don’t just analyze data or answer questions. They do the work, and do it reliably.

And they can work 24/7 on your entire entry history back to spring 2025.

What you should do right now

Don’t wait for the courts to tell you how this ends. Know where you stand and what you need to have ready.

Start with the basics: how much did you pay in IEEPA duties, and on which entries? Gather your documentation. Talk to your accounting team about when to recognize a receivable, because that $170 billion isn’t theoretical anymore. The Supreme Court’s decision confirmed these import duties may never have been legally owed.

The companies that move first — exposure quantified, documentation organized, filing strategy ready for whatever process emerges — will recover faster and recover more. The rest will be fighting over scraps in a system that was never built for this.

Our agents are ready to help. Send us your entries and we’ll show you what you’re owed, and how we can put you in the best position to get it back.

For a comprehensive guide with filing deadlines, required documentation, and step-by-step instructions, see our IEEPA Tariff Recovery Guide.

Frequently asked questions

How much are the tariff refunds worth?

An estimated $166 billion in collected duties is in play, affecting over 330,000 importers across 53 million customs entries.

Can my company get a tariff refund?

All entries on which IEEPA duties were paid are expected to be eligible for refunds. CBP’s CAPE system will process refunds in phases — Phase 1 launches April 20 and covers approximately 63% of affected entries. Future phases will cover finalized entries, complex cases, and entries requiring additional processing.

What should importers do right now about tariff refunds?

Register for electronic ACH refunds in the ACE Portal if you haven’t already — 22% of affected importers have not, and CBP will only issue refunds electronically. Identify which of your entries qualify for CAPE Phase 1 (unliquidated or within 90-day reliquidation window), organize your documentation, and confirm your ACE Portal access is current. See our IEEPA Tariff Recovery Guide for the full action checklist.

Can AI help with tariff recovery?

Yes. Tariff recovery is repetitive, document-intensive, high-volume work — exactly the kind of task AI agents are built for. AI can classify entries, cross-reference documentation, and prepare filings at a scale humans cannot match.

What is the IEEPA tariff ruling?

The Supreme Court ruled in February 2026 that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs, striking down import duties that generated an estimated $170 billion in revenue. The decision means these duties may have been collected unlawfully, opening the door to refund claims by importers.