Tariff Refunds: The Operational Nightmare Businesses Aren’t Ready For

Current Landscape of Tariff Updates

The U.S. Supreme Court is hearing arguments this week on whether Trump’s emergency tariffs were legal. Coverage focuses on constitutional questions and economic forecasts.

Yet almost no one is addressing the operational question: if tariffs get struck down, will companies be able to prove what they’re owed?

It can only be assumed that the chaos that followed the escalation of tariffs could be even messier to untangle in reverse.

Treasury Secretary Scott Bessent told NBC the government might need to refund “about half the tariffs”—potentially $750 billion to $1 trillion—if the Court delays its ruling until mid-2026. He called unwinding that amount “significant disruption.”

Two Potential Outcomes of Tariff Refunds

U.S. Customs and Border Protection (CBP) could handle refunds one of two ways:

• The easy way: Use the tariff classification codes already embedded in every import entry to identify affected shipments and process automatic refunds through their ACH system.
• The hard way: Require every importer to file individual refund requests for each and every affected entry. For unliquidated entries, that means Post Summary Corrections. For liquidated entries, it would mean administrative protests.

NOTE: The CBP has done “the easy way” before. When the Generalized System of Preferences program lapsed in 2018, CBP issued automatic refunds to importers who’d filed electronically with the proper codes. The process took about three months.

The CBP processes roughly 105,000 merchandise entries daily. That number climbed in 2025 when millions of de minimis packages became subject to formal entry requirements. If refunds require individual requests, large, sophisticated importers with dedicated trade compliance teams will recover their money. Smaller operators will struggle.

Furthermore, court filings have already warned that refunds would be “chaotic and administratively burdensome.”

The Data Problem Most Companies Haven’t Considered

Even if the CBP chooses the easy path, most importers face an internal challenge: they don’t have the resources to perform the investigation needed to prove what they’re owed.

Tariff duties get paid at the entry level, often by customs brokers working from commercial invoices. Those payments flow to the CBP. The corresponding costs flow into ERP systems, sometimes as separate line items, sometimes absorbed into landed cost calculations, and other times handled entirely outside the primary accounting system.

Most finance teams lack visibility into which orders paid emergency tariffs, how much was collected, and even what the refund amount should be.

The knowledge gap created by emergency tariffs is the same one that surfaced during tariff escalation when buyers asked for analytics showing margin impact by SKU. Most systems couldn’t answer because tariff costs and product costs lived in different places.

The Unpredictable Timeline of Tariff Refunds

Refunds won’t arrive uniformly. Rather,

1. Entries filed electronically with proper Chapter 99 classification codes would get processed first.
2. Entries requiring manual review would take longer.
3. Entries where importers missed filing deadlines or didn’t maintain proper documentation might never get refunded.

Meanwhile, companies will need to decide whether or not they should:

• Wait for refunds to hit their bank account before adjusting pricing
• Pass expected refunds through to customers immediately
• Or absorb costs to rebuild margin that compressed during tariff implementation

Each choice has second-order effects:

• If you lower prices before receiving refunds, you’re betting on a timely government processing speed and your own documentation quality.
• If you wait, competitors who moved faster capture market share.
• If you absorb refunds without adjusting prices, you’re making a margin decision that may or may not align with how you handled the original tariff increases.

None of these choices can be made confidently without knowing which SKUs were affected, by how much, and what the timelines were.

The Invoice Problem

When tariffs increased, many suppliers changed how they presented costs. Some added explicit tariff line items to invoices. Others built tariff costs into product pricing to keep EDI documents clean. Some used separate statements or periodic true ups.

If refunds come through, the way they chose to document and communicate these costs will determine how easily businesses can reconcile what they’re owed against what they receive.

• Companies that kept tariffs as separate line items can trace costs more easily.
• Companies that absorbed tariffs into base pricing will need to reconstruct cost basis by entry date and classification code.
• Companies that handled tariffs outside their primary invoice flow may struggle to connect refunds back to specific products or customers.

The competitive advantage goes to whoever maintained clean data architecture when tariffs were implemented. The penalty for messy systems won’t be obvious until refund checks arrive, and, when they do arrive, there could be challenges around tying those refunds to individual SKUs and timelines.

Leveraging B2B Data Exchange for Refund-Readiness

Most companies thinking about refund readiness are asking the wrong questions. They’re wondering if they should be exploring new solutions, AI-capabilities, or specialized partners to figure this out.

The better question is: Is there a way to connect the data you’re already exchanging?

Your B2B transactions contain most of what you need to defend a refund claim and decide what to do with the recovered margin. Purchase orders and acknowledgments establish which SKUs were ordered, at what cost, and on what date. Advanced ship notices timestamp when items are moved through your supply chain. Invoices show where tariffs were embedded or separated, and how adjustments were handled.

The challenge isn’t missing data. It’s that these documents live in separate systems that don’t talk to each other.

• When a broker is filing an entry with Customs, they’re working from commercial invoices.
• When finance is booking costs, they’re pulling from ERP.
• When operations teams are tracking inventory, they’re logging into warehouse management systems.
• When you need to reconcile a refund against what you actually paid, you’re manually connecting pieces that should already be joined.

Four Key Questions to Check your Refund-Readiness

1. Do all purchase orders that became shipments have corresponding ASNs and invoices? Gaps mean weaker traceability when reconciling what the government sends back.
2. What’s the lag between order, shipment, warehouse receipt, and invoice? Large or variable gaps complicate matching entries to physical flows.
3. What percentage of invoices reconcile cleanly to shipments at the carton and SKU level? Low match rates signal data quality problems auditors will question.
4. Which items were direct import where your customer was importer of record? Refund proceeds likely flow to them, not you.

Conversations Between Trading Partners

Like all things in the supply chain, there are many wrinkles that must be ironed out between trading partners.

For buying orgs working with brands on direct import programs, there are three questions to consider with your partners:

• Who receives the refund on each flow, and if it’s shared, how? Through redit memos, future cost adjustments, or allowances?
• What documentation validates pass-through? Entry numbers, tariff codes, duty amounts, payment dates?
• What cadence for reconciliation keeps the exchange stable while finance books cash?

For anyone working with customs brokers:

• Can you provide machine-readable files showing entry number, tariff classification, duty paid, importer of record, and ACH refund dates per line item?
• How will you flag corrected entries or reclassifications to avoid double-counts?

For 3PLs handling your inventory:

• Can we rely on warehouse confirmation timestamps and carton details to align physical receipt with entry dates?
• What’s the cleanest source of truth for carton IDs that tie back to ship notices?

The practical answer is unifying your transaction spine (purchase orders, shipments, receipts, invoices, adjustments) with effective-date pricing. That creates a connected dataset showing which entries paid tariffs, what those entries contained, what you invoiced, and what margin resulted.

From there you can identify coverage gaps by trading partner, measure timeliness, flag direct import flows where refunds accrue elsewhere, and standardize how credits or price adjustments flow through without breaking document exchange.

In Closing

The heart of the issue is not tariff refunds. Refunds, rather, are creating the opportunity for building resilience by connecting commercial decisions and operational execution, helping you understand the impact of disruptions and make smarter decisions in the face of them.

TL;DR

If tariff refunds land, the winners will be the teams that can:

• Prove what they’re owed
• Reconcile it quickly to items, customers, and periods
• Deploy the cash without creating pricing chaos, disrupting ASN/EDI flows, or damaging relationships

Align Your Data with SPS EDI

Organizations that have good visibility into their EDI documents can stay one step ahead of tariff refunds by keeping their systems in conversation with each other. Check out our EDI solutions with SPS Fulfillment to see if joining the network is right for your business.