Your tariff refund may be sitting under someone else’s name
A tariff refund goes to one name on one customs form. Here's how to read that form and see which entries are running out of time.
If your brand imported goods between February 2025 and February 2026, a tariff refund may be waiting for you, with interest.
It goes only to the importer of record. That may not be you.
These are the IEEPA tariffs the Supreme Court struck down on Feb 20. Where your money stands comes down to one customs document, CBP Form 7501. Most founders have never opened one.
Your broker or forwarder should have yours. Let’s read it. Only four boxes matter here.
Box 30: the refund follows this name
CBP says it can only pay the importer of record or a party they name on Form 4811. Who ended up carrying the cost doesn’t change that.
For a DTC brand, box 30 usually holds one of three names.
You. You, or the broker who filed the entries, can claim it.
Your carrier. On parcels, FedEx, UPS or DHL may be the importer. They collect the refund, then pay it on. FedEx said it would offer a portal to check each shipment. UPS said it would settle open invoices first. DHL estimated 30 to 90 days after it gets paid.
Your supplier. On DDP terms, the seller or its agent is often the importer. Then the claim is theirs, and your share depends on your contract. Ask whether they’d name you on Form 4811.
One text to your broker tonight: “Whose number is in box 27 on my 2025 entries?”
Box 7: the entry date sets your clock
Customs closes out, or liquidates, an entry on a 314-day cycle. Two timers start there.
CAPE, CBP’s refund system, takes entries that are unliquidated or liquidated within the last 80 days. The protest window runs to day 180. After that, the entry is final.
Run that against today’s date and your entries fall into three lanes.
Watch that Oct 4 line. It moves a day every day, and it’s walking through the weeks when many brands landed last year’s holiday stock.
CAPE open: file. Don’t protest these. CAPE doesn’t take entries under open protest yet.
Protest window: consider a protest while the 180 days run.
Final: the hard road. CAPE Phase 3 opened Oct 6, only for importers with their own court order. On Oct 8 the trade court certified a class of importers who paid through Feb 19, 2026, which may help those who never sued. It doesn’t order refunds yet, an appeal is expected, and goods under the Brazil and India orders aren’t covered.
Davis Wright Tremaine’s lawyers put the earliest end of the window to sue at Feb 4, 2027. Diaz Trade Law says to calendar it as if the class didn’t exist.
Box 1: your claim is a list of numbers
You don’t write a letter. CAPE takes a CSV of entry numbers through the ACE Portal.
An ACE account can take up to six weeks. If a broker filed your entries, ask them to file this too.
Then there’s the bank. CBP pays by ACH only, and this is where money quietly stalls.
CBP says valid refunds generally land 60 to 90 days after acceptance. Accepted by mid-November, that points to mid-January through mid-February.
Box 41: treat this as one-time money
Box 41 is all the duty on the entry. Only the IEEPA part comes back, and CBP warns the amount may not match your math.
Tariffs didn’t end, either. New Section 301 duties of 10% or 12.5% began July 24. So we’d book the refund when it lands, as one-time cash, and build no price on it.
Customers have noticed too. By July there were more than 100 proposed class actions arguing that companies can’t keep both a tariff price rise and the refund. Thompson Coburn’s advice: document how tariffs moved your pricing, and don’t promise customers a share yet.
Look at your store with that in mind. The tariff banner, the FAQ line, the fee at checkout. Ask your lawyer what stays, and change it before your BFCM freeze.
What to do this week
- Ask your broker for every 2025 entry, with importer number, entry date and liquidation date.
- Sort them into the three lanes. File the open lane first.
- Check your ACH setup and Form 5106. Baker Tilly says CBP now voids importer numbers when that data is wrong.
- Chase the other names. Carrier first, then your supplier, in writing.
- Talk to a customs broker or trade lawyer. We build stores. This post isn’t legal advice.
CBP won’t email you about any of this, so nobody is going to remind you.
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