UHY Helped One Importer Recovered $7.5 Million in IEEPA Tariffs. What Could You Recover?5 Min Read

As we assist clients in navigating tariff pressure unlike anything most business owners have seen before, we emphasize compliance, financial management, and improvement, in that order. Each time a new code or statute is introduced, we work with clients to make sure they are compliant to avoid any additional penalties or actions, we talk about how to handle the added “landed cost”, and finally we begin to discuss how they can improve their overall tariff position through a variety of strategies.

Refund eligibility and execution is an additional step that depends on the client’s exposure. It begins with a careful analysis of overall tariff burden and examination of the specific HTS codes and product classifications to ensure accurate assessment. From there, we guide clients through setting up an ACE portal account so they can use the CAPE system to process and receive their refund.

This particular client is a leading global manufacturer of metal forging and precision laser cutting equipment with over $50 million in revenue.

More than $10 million in tariffs, but limited visibility

Between February 2025 and March 2026, the company imported more than $83 million in goods and paid over $10 million in duties and tariffs.

Its import entries contained multiple Harmonized Tariff Schedule (HTS) codes, but the company lacked visibility into how those codes connected to specific tariffs. That made it difficult to determine how much had been paid under the International Emergency Economic Powers Act (IEEPA) and how much could potentially be recovered.

Identifying the eligible IEEPA tariffs

Using reports and import data provided by the company, UHY analyzed the underlying tariff codes and individual entries. Advanced artificial intelligence tools helped process the data, with findings cross-verified against the official U.S. Harmonized Tariff Schedule.

The analysis isolated the applicable IEEPA tariffs and identified the entries eligible for the first phase of the refund process, including unliquidated entries and qualifying entries within the applicable post-liquidation window.

The initial analysis estimated a potential refund of approximately $9 million.

Preparing and submitting the claim

Before submission, UHY verified that the company's contact and banking information matched U.S. Customs and Border Protection (CBP) records, helping avoid administrative delays.

With access to the company's Automated Commercial Environment (ACE) portal, UHY prepared the eligible entry numbers and submitted them through CBP's CAPE system.

UHY then used ACE reporting to monitor the claim weekly as CBP processed the eligible entries and issued refunds in batches based on their liquidation dates.

Why the final refund differed from the initial estimate

As UHY validated the entries, the analysis uncovered a reporting issue tied to the way IEEPA tariffs on European Union imports were structured beginning in August 2025. Under the revised framework, the combined base Most Favored Nation (MFN) duty and IEEPA tariff were capped at 15%.

That change created complexity in how the duties were reported. In some cases, the company's customs broker grouped the base MFN duty and IEEPA tariff under a single HTS code, causing the original reports to overstate the amount attributable specifically to IEEPA. For example, if the base MFN duty was 4.7%, the IEEPA portion was 10.3%, rather than an additional 15%.

Correcting for that reporting treatment reduced the refund from the initial estimate, while ensuring the final claim accurately reflected the IEEPA tariffs eligible for recovery.

Approximately $7.5 million recovered, plus interest

The company ultimately recovered approximately $7.5 million in IEEPA tariffs, plus interest.

The engagement also gave the company greater visibility into its tariff costs and highlighted the importance of reviewing entry-level customs data rather than relying solely on aggregate broker reports.

Evaluate your potential IEEPA tariff recovery

For companies with significant import activity, determining potential IEEPA refunds can require detailed analysis of HTS codes, duty calculations, liquidation status and customs reporting.

UHY helps companies identify eligible tariff payments, prepare refund claims and monitor recovery through completion. If your organization paid IEEPA tariffs, now is the time to determine what may be recoverable. Fill out the form on this page to discuss your tariff position and your IEEPA refund eligibility.

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