On February 20, 2026, the Supreme Court issued its ruling in Learning Resources, Inc. v. Trump. The headline outcome: IEEPA tariffs collected between February 2025 and February 2026 are refundable, with 6 percent statutory interest, to importers of record who paid them on qualifying entries.
That is the short version. The longer version is what determines whether a specific company is actually positioned to recover its money, and the difference is in the entry data.
What "eligible" actually means
Three conditions need to hold for an importer to be in line for a refund.
The company was the importer of record on the affected entries. The IOR is the legal party that filed the entry summary with CBP and paid the duties at clearance. In most cases this is the U.S. company that owns the goods at the point of entry, but it can also be a customs broker filing on the company's behalf or a foreign exporter using a U.S. IOR service. The party that paid the duty is the party that can recover it.
The duties paid were IEEPA tariffs specifically. Imports between February 2025 and February 2026 often had multiple duty types stacked on a single entry. IEEPA tariffs were the new layer that the Learning Resources ruling addressed. Section 232 tariffs (steel, aluminum, certain auto parts) and Section 301 tariffs (the China-specific layer that has been in place since 2018) are separate authorities, separate proclamations, and not affected by this ruling. The refundable portion is the IEEPA portion only.
The entries are not yet liquidated past the statutory protest window. Liquidation is the CBP process that makes a duty determination final. Liquidated entries past the 180-day protest window have a different procedural path to refund recovery, generally requiring formal protests or court action rather than direct refund filing.
The first two conditions are usually clean. The third one is where many entries from early 2025 are starting to sit, and timing matters.
The industries the ruling reaches
IEEPA tariffs hit broadly. The industries with the most concentrated exposure, based on entry data published by trade research firms:
Apparel and textiles, particularly imports from China, Vietnam, and Bangladesh.
Automotive parts and vehicles, particularly imports from Mexico, Canada, and Asia.
Consumer electronics, where the entire supply chain runs through countries that fell under IEEPA's scope.
Consumer goods and retail, with heavy exposure on imports from Asia and Mexico.
Distribution and wholesale operations sourcing from affected origins.
E-commerce platforms with private-label sourcing.
Food and beverage, particularly specialty importers and produce.
Industrial equipment and machinery, with heavy exposure on imports from China and Europe.
Manufacturing operations using imported components or raw materials.
Specialty importing and logistics operations.
The pattern across all of these is the same. A company that ran $5 million to $100 million plus in imports during the affected window, with an average IEEPA-attributable rate of 10 to 25 percent of declared value, is sitting on a refund position in the low six figures to the high seven figures, sometimes higher.
What "organize now" means in practice
CBP's CAPE module (the system that will handle IEEPA refund filings) is not yet publicly accessible as of source materials reviewed in May 2026. Once CAPE opens, the projected filing window is 45 to 60 days based on current guidance. After the filing window closes, a 180-day appeal period follows for entries that get rejected on first submission.
The companies positioned to file the day CAPE opens are the ones that have already done the entry-data work. The companies that wait until CAPE opens to start the work will spend the entire filing window assembling data instead of submitting it.
Three things need to be in order before the window opens.
ACE entry data, separated by duty type. The Automated Commercial Environment is CBP's system of record for entry data. The data the importer needs is already there, but it needs to be pulled and organized by duty type. IEEPA, Section 232, Section 301, and regular MFN duties all need to be separable on each entry. Most customs brokers can produce this. Many have not yet been asked.
Liquidation status per entry. The status determines the procedural path. Unliquidated entries follow one path. Liquidated entries within the 180-day protest window follow another. Liquidated entries past the protest window follow a third path, which is significantly more complex.
Broker confirmation that entry summaries match what was actually paid. Discrepancies between the entry summary and the actual remittance happen more often than most importers realize, particularly on consolidated entries or entries with subsequent corrections. Reconciling these before filing avoids a CBP rejection during the window, when there is no time to fix it.
The work is not exotic. It is administrative. The companies that are doing it now are positioned to file. The companies that are not doing it now are positioned to scramble.
The 6 percent interest component
The Learning Resources ruling included a 6 percent statutory interest provision on the refundable duties. This is not a small line item.
A company that paid $2 million in IEEPA tariffs in May 2025 has accrued roughly $120,000 in statutory interest by May 2026. The interest accrues from the date of payment until the refund is issued. The longer the wait between filing and refund, the larger the interest component.
This changes the math on whether to wait. A company that files in the first week CAPE opens and receives the refund within 90 to 180 days will see the statutory interest stop accruing at that point. A company that files in the last week of the window and gets caught in a 6 to 12 month CBP processing queue will see the interest continue accruing the entire time, which is a real cash component on a real receivable.
The interest math is one of the reasons importers with larger claims are actively choosing a structured early-filing approach over a do-it-yourself path that may not complete within the window.
What CBP will not do
A few things to be clear about, because the category gets mischaracterized.
CBP will not proactively identify or refund eligible duties. The refund process is filing-driven. The importer (or its agent) has to submit the claim with the supporting entry data within the window.
CBP will not extend the filing window for companies that were not ready. The 45-to-60 day window is procedural. Entries not filed in the window have to go through the post-window protest and appeal process, which is slower, more contested, and not guaranteed.
CBP will not refund duties that cannot be cleanly attributed to IEEPA on the entry data. Mixed entries where IEEPA and Section 232/301 duties were stacked without clean attribution will require additional documentation, which slows the refund and increases the rejection risk.
The CBP process is structured to favor the importers who came prepared.
What the path forward looks like
There are essentially three paths an importer can take.
Path one is fully in-house. The importer's own trade compliance team handles the entry-data organization, the filing, the CBP communications, and the receivable management. This works for companies with mature in-house customs functions, typically those with multi-billion-dollar import volumes and dedicated trade compliance staff.
Path two is broker-led. The customs broker who filed the original entries handles the refund filing. Many brokers are equipped to do this for smaller-volume claims. The constraint is broker capacity during the filing window, which will be tight given that every importer's broker will be doing this work simultaneously.
Path three is structured through a capital partner. Companies in this category use a specialized provider that handles end-to-end refund recovery, including the option to receive the expected refund as upfront liquidity in roughly two to three weeks rather than waiting on CBP's processing pipeline. The capital partner essentially purchases or advances against the receivable, takes on the timing risk, and collects when CBP issues the refund.
Path three is what most mid-market importers in the affected industries are evaluating, because it solves two problems at once: the working-capital problem (cash now versus cash in six to twelve months) and the filing-bandwidth problem (specialized capacity versus broker queue).
The honest framing
Stone Path facilitates the introduction to a vetted capital partner that runs a structured File and Fund process for importers in this category. Stone Path is not the capital partner, is not a customs broker, and does not provide legal advice on tariff classification or refund eligibility. The introduction is upstream of the diligence work, which the capital partner and its partner law firms handle directly.
The refundable pool sitting in the system is large. Industry research firms have reported more than $166 billion was collected in IEEPA tariffs across roughly 53 million entries during the affected window. That is the order of magnitude of what is recoverable across all importers.
The refund opportunity has a sunset. Once CAPE opens and the filing window closes, the procedural path to recovery becomes substantially harder. Current industry projections point to the practical filing window closing in early November 2026. Importers that organize entry data now are positioned. Importers that do not are not.
Walk through whether your import entries qualify and we will scope what the recovery path looks like for your specific entry profile.