On 20 February 2026, the US Supreme Court ruled that the tariffs imposed under the International Emergency Economic Powers Act (IEEPA) were unlawful. US Customs and Border Protection (CBP) was instructed to refund those tariffs, plus interest, to whoever was the Importer of Record (IOR) on the shipment. The IOR is typically the carrier (DHL or FedEx), but can also be you as the merchant — or in some cases the end consumer, if the shipment is valued over $2,500 and they have completed a Form 5106.
Important: This refund only covers the IEEPA-based tariffs — the 10%+ baseline reciprocal tariff, country-specific elevated rates, and the 25% Canada/Mexico tariff. It does not cover Section 301 China tariffs, Section 232 steel/aluminium/auto tariffs, antidumping/countervailing duties, or the new Section 122 tariff (10%, rising to 15%) that replaced IEEPA from 24 February 2026 — that one is separate and still payable.
Where things stand today (22 July 2026)
If DHL was your Importer of Record
DHL is already filing on your behalf and has started issuing IEEPA credits directly to DHL accounts, in phases. You don't need to do anything — DHL will refund you automatically as CBP processes each refund. Only the IEEPA portion is credited; other duties still apply.
If FedEx was your Importer of Record
Swap now has direct access to FedEx's IEEPA refund portal and our Cross-Border team is actively submitting eligible shipments on your behalf. Because the portal only accepts 100 entries per submission and there are several hundred thousand shipments to work through, this is being processed in batches — our team started working through it on 22 July 2026.
If you were your own Importer of Record
You'll need to file directly with CBP through their ACE portal, or via your own customs broker. Swap can help provide the underlying shipment data to support that claim, but cannot file it on your behalf in this scenario.
Timeline — what to expect
This is a genuine, active process, but it is not instant, and CBP — not Swap or the carrier — controls the pace. Once a claim is submitted:
CBP is processing refunds in phases. Phase 1 (entries closest to liquidation) has been paying out since 11 May 2026. Phase 2 (entries flagged for reconciliation) was targeted to open 29 June 2026. Phase 3 (fully liquidated/complex entries) was targeted to open 31 July 2026, and eligibility for Phase 3 is still uncertain and being addressed in the courts — not every shipment is guaranteed to qualify.
Typical processing time from submission to funds landing is 1–5 months, but this is subject to change depending on the pace of CBP.
Refunds arrive as a direct payment to whoever was the Importer of Record (the carrier, in most cases) — not directly to you as the merchant. Where Swap or the carrier receives the funds, a reconciliation step is still needed to match refunds back to the correct merchant, since these come through as many individual payments rather than one lump sum.
We'll provide updates as batches are submitted and as refunds start to land — please treat any timeline as an estimate, not a commitment, since it depends on CBP's processing speed.
Frequently asked questions
Has my refund already been approved?
We can confirm whether your shipment has been submitted for a refund. We cannot confirm CBP has approved or paid it until that actually happens — CBP, not Swap, makes that determination.
Why hasn't everything been refunded yet?
CBP is working through this in phases and has not yet completed Phase 2 or Phase 3 for all eligible shipments. Many shipments are still waiting on CBP, not on Swap or the carrier.
Will the new 10% tariff also be refunded?
No. That's a separate charge (Section 122), introduced after the IEEPA tariffs were struck down. It is not part of this refund and remains payable.
How much will I get back?
We can't quote a figure until CBP has processed and paid the specific claim. Total value depends on your shipment volume and the tariffs originally charged.
What do I need to do?
If DHL or FedEx was your Importer of Record, nothing — Swap and the carrier are handling the filing. If you were your own Importer of Record, you'll need to file directly with CBP or your broker; contact your Swap account manager if you'd like help pulling the underlying shipment data.