Frequently Asked Questions about IEEPA Tariff Refunds
As of February 20th, 2026, the US Supreme Court struck down all tariffs invoked under the IEEPA (International Emergency Economic Powers Act). As a consequence of this, the tariffs that were collected under those rules now must be refunded. We’ve been getting a lot of questions on how this process is going to work with DHL shipments as they are our carrier of choice. If you imported something to the United States using DHL from Feb of 2025 through March 2026, here’s what you need to know about the refund process.
What Shipments are Eligible for IEEPA Tariff Refunds?
Right now (as of May 6th, 2025), Customs and Border Patrol (CBP) have limited the eligibility of IEEPA tariff refunds only to what is considered a Phase I shipment.
Phase I is limited to:
- Formal entries (valued above $2500 or requiring other government agencies) with entry summary date (this is the day duties were paid to CBP) less than 394 days ago.
- For example, using April 20, 2026 as start date for CAPE (Consolidated Administration and Processing of Entries), this means entries from March 22, 2025 through February 24, 2026 would be eligible absent any other exclusions.
- Informal entries filed electronically via ACE (Automated Commercial Environment) with entry summary date less than 80 days ago.
- For example, starting with submissions on April 20, 2026, this would mean entries from January 30, 2026 through February 24, 2026 would be eligible absent any other exclusions.
How do I know who needs to apply for the IEEPA refund?
This all has to do with who the Importer of Record (IOR) was for the shipment in question. If DHL was the IOR, they will take care of applying for the refund. If your company was the IOR, then you will need to apply for the refund yourself, or you can hire DHL to file for you for a $2.10 fee per entry.
How do I know if I was the Import of Record (IOR) on my DHL shipment(s)?
If you look at the customs entry documents for the shipment, the IOR will be displayed in box 11 or 26 (depending on the form).
Additionally, if you are registered on Customs and Border Patrol’s ACE portal, you can run a report of all the entries associated with your Importer of Record Number.
Note: Your IOR # is typically your EIN with two zeros at the end. i.e. XX-XXXXXXX00
How long will it take to receive the refund?*
- If your company was the IOR, you should expect to receive their refund into your ACE ACH account within 60-90 days from when their CAPE claim was accepted by CBP.
- If you already have an ACE account, you can file a refund request through CAPE. CBP instructions can be found here.
- If you don't have an ACE account and/or don't wish to self-file, you can request DHL to file on your behalf. To do so, you must provide the list of applicable and eligible entry numbers/airway bills.
- If DHL was the IOR, it is estimated that it will take an additional 30-90 days from DHL’s receipt of the refund to be able to reconcile and process payments to the customers who originally paid the duty at time of import:
- DTP (Duty Taxes Paid): Origin or 3rd party account billed for duty and tax at the time of original import.
- DTU (Duty Taxes Unpaid): Destination party who was invoiced and paid duty and tax
*This is based on current CBP and DHL communication and is subject to change
**Please also be aware that this is general information. OptimalShip DHL is not legal counsel on this matter if you are seeking legal options.
Conclusion
There’s a lot to this process, so we will continue to do our best to make sure our clients and non-clients alike are notified of changes. This blog will continue to be updated as we receive more information. If you’d like help through this process, we are more than happy to assist our clients with this and many more shipping and logistics services.
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