On May 16, 2025, U.S. Customs and Border Protection (CBP) began processing refunds tied to overpaid duties resulting from tariff stacking—where multiple overlapping tariffs were applied to the same import entry. The refund mechanism follows Executive Order 14289, signed April 29, which prohibits cumulative tariff application across certain national security and emergency-based trade actions.
The implementation applies retroactively to all covered articles entered for consumption, or withdrawn from warehouse for consumption, on or after March 4, 2025.
IMPORTS ELIGIBLE FOR TARIFF STACKING REFUNDS
CBP will issue refunds for importers whose entries were assessed more than one tariff under the specific authorities addressed in the Executive Order:
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Section 232 auto and auto parts tariffs
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Section 232 aluminum and steel tariffs
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IEEPA-based duties targeting illicit drug flows from Canada and Mexico
Entries that fall under more than one of these programs are now subject to a tariff ordering framework that limits application to a single applicable duty, with narrow exceptions for aluminum and steel stacking.
Not All Duties Qualify for Relief
Only tariffs covered by Executive Order 14289 are eligible. Duties imposed under Section 301, antidumping/countervailing duties (AD/CVD), and synthetic opioid enforcement actions remain fully enforceable and are not affected by the refund provisions.
STEPS TO REQUEST A REFUND AND COMPLY WITH NEW DUTY TREATMENT
CBP is not issuing automatic refunds. U.S. importers must take formal steps to recover overpaid duties and align with the revised tariff framework.
To request a tariff overpayment refund, importers should:
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Review all entries made on or after March 4, 2025, for overlapping tariff applications covered under Executive Order 14289
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Validate current HTS classifications using the revised Harmonized Tariff Schedule of the United States (HTSUS) annotations
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File a Post Summary Correction (PSC) for any qualifying unliquidated entries in ACE
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Submit a Protest under 19 U.S.C. §1514 for liquidated entries still within the 180-day protest window
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Maintain audit-ready records documenting refund efforts and HTS compliance updates
Refunds will be calculated using the corrected duty treatment under the new tariff prioritization rules. CBP’s implementation of Executive Order 14289 represents an opportunity for cost recovery provided importers act quickly to meet filing deadlines and submit accurate HTS classifications.
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