The Supreme Court’s February 2026 decision striking down broad IEEPA tariffs has triggered a complex refund process, now centered at the CIT and being implemented by the CBP. The main action items are straightforward. Importers should track liquidation dates, confirm ACH and ACE enrollment, preserve all entry and payment records, and review any contracts that may affect refund sharing. Wholesalers and distributors should check whether their pricing or surcharge provisions address tariff reimbursement. All parties should continue monitoring CBP’s rollout, the CIT’s next orders, and any appeal activity that could affect the scope or timing of refunds. For businesses, the key distinction is between legal entitlement and commercial recovery. Importers of record are positioned to receive refunds directly, provided they maintain proper documentation and system readiness. In contrast, wholesalers and distributors must rely on contract terms to determine whether they share in any recovered duties, making careful review of agreements essential. NAED – Washington Wire