Arlington, VA – October 7, 2026 – Seven months after the Supreme Court struck down tariffs imposed under the International Emergency Economic Powers Act (IEEPA), most manufacturers are getting money back but few have recovered all of it, according to new analysis from Manufacturers Alliance.
How are IEEPA tariff refunds progressing for manufacturers in 2026?
Faster than expected, but incomplete. Every manufacturer that filed a Phase 2 claim has received at least some money, and 80% received their first refund within about 60 days, quicker than CBP's own guidance of 60 to 90 days. But 76% of Phase 2 filers have been refunded only in part, and just 24% report full refunds.
Why are manufacturers receiving only partial refunds?
Often, they don't know. 54% of partially refunded companies say CBP provided no explanation, error codes, or line-level detail on the unrefunded portion. Where companies can identify a cause, they most often point to entries not yet liquidated or reliquidated (35%) or entries outside Phase 2's scope (35%). As a result, refund tracking has become an ongoing, entry-by-entry reconciliation task for trade and finance teams rather than a one-time filing.
What should manufacturers know about Phase 3 IEEPA refund claims?
Eligibility may depend on litigation. Phase 3, which covers finally liquidated entries and opens October 6, is currently limited to plaintiffs for whom the Court of International Trade (CIT) has ordered reliquidation. 65% of surveyed manufacturers intend to file Phase 3 claims, yet 60% of those companies have not filed their own CIT action.
Key Findings:
The IEEPA refund process is working, but unevenly, and the hardest part of recovery may still be ahead.
- Refunds are arriving quickly. 40% of manufacturers received their first refund within 30 days of filing, and the fastest reported receiving one in two weeks.
- Most claims remain only partly paid. 76% of Phase 2 filers are still waiting on part of their refund, often with no explanation from CBP.
- Brokers are a second bottleneck. Only 44% of manufacturers with broker-handled Phase 1 refunds have received them in full, and 39% report that some money is still held by their broker.
- Phase 3 plans may outrun eligibility. Most manufacturers plan to file, but a majority of those planning to file have not taken the legal step Phase 3 currently requires.
- Companies are keeping the work in-house. 61% plan to use internal trade or compliance teams to prepare and submit their Phase 3 claims.
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