The IEEPA Tariff Refund Playbook
A structured approach to recovering supplier tariff costs following the 2026 Supreme Court IEEPA ruling: who's owed money, how the refund actually flows, and a step-by-step claim framework for finance and procurement teams.
Why this opportunity exists
Many procurement organizations absorbed supplier price increases during 2025 that were driven, at least in part, by IEEPA tariffs. Following the Supreme Court's February 2026 ruling, up to $175 billion in IEEPA duties became potentially subject to refund.
Here's the catch: in many cases that refund flows to the supplier, because the supplier was the importer of record, not the customer who ultimately absorbed the higher price. The money does not come back to you automatically. Someone has to go get it.
That creates a one-time window. By identifying tariff-related price increases and working with suppliers to reconcile refunds, companies can recover value that would otherwise quietly stay in the supply base. This playbook lays out the five-step process for doing exactly that, developed and pressure-tested on a live national retail engagement.
Who this is for
You likely have meaningful exposure if you purchase imported products, or domestically manufactured goods containing imported components:
- Retail & consumer goods: apparel, footwear, furniture, home goods, electronics, toys
- Food & grocery: coffee, seafood, cheese, wine and spirits, plus the glass, cans and plastic it ships in
- Manufacturing & industrial: components and subassemblies, machinery and spare parts, fasteners, circuit boards, PPE
- Automotive & aftermarket: replacement parts, tires, wire harnesses, batteries
Built on a live engagement, not a theory
A large national retailer with tariff-related price increases dispersed across hundreds of suppliers and thousands of transactions, with no centralized view of exposure.
As of August 2026. Supplier commitments are generally contingent on refund receipt.
Who wrote this
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Think you may be owed a refund?
Winters Procurement can complete a preliminary opportunity assessment in 2–3 weeks, identifying likely recovery opportunities before supplier outreach begins.
Questions? Email daly@wintersprocurement.com.
Winters Procurement is not a customs broker, law firm, tax advisor, or accounting firm. This playbook provides a commercial procurement framework and does not constitute legal, customs, tax, or accounting advice. Refund eligibility, filing rights, deadlines, contractual obligations, and accounting treatment vary by organization and transaction.