A working reference for brokers and trade counsel.
The 1977 law the President used to impose extra tariffs in 2025. The Supreme Court ruled those particular tariffs went beyond what the law allows.
IEEPA lets the President regulate commerce during a declared national emergency. The 2025 tariffs invoked it to add ad valorem (percentage-of-value) duties on imports from many countries. On Feb 20, 2026, in Learning Resources, Inc. v. Trump, the Supreme Court held these duties were not authorized by IEEPA.
The Supreme Court case, decided Feb 20, 2026, that struck down the IEEPA tariffs. It's why refunds are now on the table.
The Court held, in its own words, that “IEEPA does not authorize the President to impose tariffs.” Its reasoning was the major-questions doctrine: the power to “regulate … importation” is not the clear authorization Congress must give before the President can wield its core tariff power. The case (No. 24–1287, decided with No. 25–250) reaches us as 607 U. S. ___ (2026); the Chief Justice wrote for the Court. The Court of International Trade had ordered refunds of approximately $165 billion in unlawfully collected duties, and CBP is building the mechanism to process them.
'Ending Certain Tariff Actions' — issued the same day as the ruling (Feb 20, 2026). It stopped IEEPA duties from being collected going forward.
Signed Feb 20, 2026, this order terminated the additional IEEPA ad valorem duties across nine prior executive orders — in its words, they “shall no longer be in effect and, as soon as practicable, shall no longer be collected.” It expressly does NOT affect Section 232 or Section 301 duties, and leaves the underlying national emergencies in place. Critical asymmetry: the IEEPA codes are still listed in the published HTS, but the duties are no longer collected as of this order — a code being present in the schedule does not mean the duty is live. Whether a past entry is refundable depends on its entry date against this timeline.
A new, temporary 10% surcharge on most imports — separate from the IEEPA tariffs that were struck down. It does not affect your refund on past IEEPA duties.
By proclamation on Feb 20, 2026 (effective Feb 24), the President imposed a temporary 10% ad valorem import surcharge for 150 days under Section 122 of the Trade Act of 1974, citing balance-of-payments concerns — with carve-outs for critical minerals, energy, certain agricultural goods, pharmaceuticals, vehicles, goods already subject to other tariffs, and USMCA/CAFTA-DR origin. This is a forward-looking, separately-authorized charge. It is NOT an IEEPA duty and is NOT part of the refund here, which covers IEEPA duties already paid. How it bears on any specific shipment is a question for a licensed customs broker.
The duty-free pass for low-value shipments (under $800) stays suspended — those imports remain subject to duties and fees.
“De minimis” (19 U.S.C. 1321(a)(2)(C), often called the Section 321 exemption) historically let low-value shipments enter duty-free. An Executive Order of Feb 20, 2026 (effective Feb 24) continues the suspension of that treatment for all countries, so such shipments stay subject to applicable duties, taxes, and fees — with international postal shipments tied to the Section 122 surcharge. Like the surcharge, this is a separate, forward-looking measure and does not affect a refund of past IEEPA duties.
Tariffs on Chinese goods, separate from IEEPA. These were NOT struck down and generally still apply.
Authorized under the Trade Act of 1974 to respond to unfair trade practices. Lists 1–4A cover roughly $370B in trade at 7.5–25%. Coded under HTS 9903.88.*. If you imported from China, only the IEEPA portion of your duties is likely refundable, not the 301 portion.
National-security tariffs on steel, aluminum, and a few other goods. Also separate from IEEPA, and still in force.
Authorized under the Trade Expansion Act of 1962. Coded under HTS 9903.80–9903.85. Not part of the refund.
The official U.S. list of every import code and its duty rate. Maintained by the USITC.
Tariff overlays like IEEPA, 301, and 232 are coded under Chapter 99. The IEEPA codes live under headings 9903.01.* and 9903.02.*. The chat assistant looks these up live from the official USITC schedule.
The part of the tariff schedule that holds temporary tariff overlays — including the IEEPA duties at issue.
Example codes: 9903.01.25 (reciprocal tariff, all countries, +10%), 9903.01.26 (Canada IEEPA, +25%), 9903.01.27 (Mexico IEEPA, +25%).
The main way to fix a customs entry after the fact — and the channel used to claim an IEEPA refund.
A PSC can be filed on an unliquidated entry within 300 days of the date of entry, or up to 15 days before the scheduled liquidation date. This is why entry dates and deadlines matter.
The customs document that records what you imported and the duties you paid. Your refund is filed against these.
Pulled from your ACE Portal export. Only the importer of record can access their own entry data — there's no public download, which is why a refund claim works from your own records.
A separate refund program: if you re-exported goods, you can recover up to 99% of the duties paid on them.
The agency that publishes the official tariff schedule. TariffsGPT reads HTS codes directly from its free public API.
CBP's public database of binding rulings — its official written decisions on how specific products are classified and taxed. TariffsGPT searches it so the assistant can cite real precedent.
A binding ruling is CBP's answer to an importer's question, e.g. 'what code does my product fall under?' CROSS holds about 220,000 of them back to 1989. When the chat assistant references how goods like yours were treated, it's citing an actual CROSS ruling — not guessing.
Our label for a customs ruling that cites one of the Chapter 99 tariff codes TariffsGPT tracks — the IEEPA, Section 301, or Section 232 overlays. These are the rulings that actually bear on refund-era questions.
Most of the ~220,000 rulings in CROSS are routine classifications of ordinary goods with no connection to the 2025 tariffs. A 'regime-relevant' ruling is one whose cited codes touch a tariff program at issue here (9903.* / 9904.*). About 6,600 rulings qualify. Because these are the only ones the assistant is likely to need in depth, TariffsGPT stores their full decision text for grounding; for all other rulings it keeps the summary and links out to CROSS.
The actual decision behind every number on this site — Learning Resources, Inc. v. Trump. TariffsGPT stores the full opinion so the chat assistant can quote the Court's own words instead of paraphrasing.
Decided February 20, 2026 (No. 24–1287, consolidated with No. 25–250, Trump v. V.O.S. Selections), the Chief Justice writing for the Court. The full text of the opinion is loaded into TariffsGPT; when you ask what the Court ruled or why, the assistant quotes the holding and reasoning directly from it — not from memory. The premise of the whole product traces to one verbatim line: “IEEPA does not authorize the President to impose tariffs.”
Codes and rates drawn from the U.S. International Trade Commission (USITC) Harmonized Tariff Schedule. Refund framework per Learning Resources, Inc. v. Trump, 607 U. S. ___ (2026), and Executive Order 14389 (Feb 20, 2026). Statutory cites are provided for orientation, not as legal advice — confirm classification and eligibility with licensed counsel.