Over the past several weeks many of you have reached out asking about potential refunds tied to duties collected under tariffs imposed during the Trump administration under the International Emergency Economic Powers Act (IEEPA). Recent court rulings have created understandable confusion about whether refunds are available and how they might work. This article explains where things stand today, what Royal Coffee is doing now, and what roasters should realistically expect as the situation develops.
- No tariff refunds are available yet. The federal government has not opened the claims system required to process them.
- Only tariffs imposed under IEEPA are potentially subject to refunds. Duties collected under any other trade authority are not affected by the Supreme Court ruling.
- Refunds are issued to the Importer of Record. For green coffee shipments this is the importing company, such as Royal Coffee.
- Roasters cannot apply for refunds directly. Any claims must be filed by the importer through U.S. Customs and Border Protection.
- Royal Coffee is preparing claims now so we can act as soon as the federal system becomes available.
- There is nothing customers need to file or submit at this time.
- Once the government begins issuing refunds and the scope becomes clear, Royal Coffee will communicate how reconciliation with customers will occur.
The Short Version
On February 20, 2026, the U.S. Supreme Court ruled in Learning Resources v. Trump that tariffs imposed under IEEPA were unlawful, striking down the entire regime. The ruling established that duties collected under IEEPA were not legally authorized. However, refunds are not currently being issued. The federal government must first build the administrative system required to process refund claims.
Under U.S. customs law, refunds are issued to the Importer of Record — the company listed on the customs entry when goods enter the United States. In the green coffee supply chain, this is typically the importing company such as Royal Coffee, which pays duties directly to the federal government. If refunds are issued, they will first be paid to Royal Coffee through CBP. Importers then determine how those funds should be reconciled with affected customers.
It is also important to note that only tariffs collected under IEEPA are potentially eligible for refunds. Tariffs imposed under other legal authorities are not affected by this ruling. At this stage, there is nothing roasters need to file or request.
Industry Context
The scale of the IEEPA tariff program helps explain why the refund process will take time. According to public reporting, U.S. Customs and Border Protection collected duties on more than 53 million import entries involving over 330,000 importers while the IEEPA tariffs were in effect. Those entries span nearly every sector of the U.S. import economy, from consumer goods and electronics to industrial materials and agricultural products.
Coffee imports represent only a small portion of that total. However, processing refunds across millions of entries requires new administrative infrastructure. CBP’s existing systems were not designed to handle refunds at this scale. The agency is now developing new tools within its Automated Commercial Environment (ACE) platform that will allow refund claims to be processed electronically rather than through manual case-by-case review. Until that system is operational, no importer in any industry can submit refund claims or receive payments.
Timeline of Key Events
- February 2025 The Trump administration began imposing tariffs on a range of imports using authority claimed under IEEPA.
- February 2025 – February 2026 Importers across multiple industries paid duties on millions of entries while legal challenges moved through the courts.
- February 20, 2026 The U.S. Supreme Court ruled in Learning Resources v. Trump that tariffs imposed under IEEPA were unlawful, striking them down.
- November 14, 2025 Coffee was among certain food products exempted from IEEPA tariffs.
- February – March 2026 U.S. Customs and Border Protection began developing an administrative process to review affected entries and issue refunds.
- March 4, 2026 The U.S. Court of International Trade ordered CBP to begin processing refunds for all affected entries.
- March 6, 2026 The Court of International Trade suspended its own order after CBP filed a declaration explaining that its existing systems could not handle refunds at this scale and needed time to build new infrastructure.
- March 12, 2026 CBP reported that the new claims system is more than 40% complete.
- Spring 2026 (Projected) CBP has indicated that a claims system within ACE may become operational in mid-to-late April, though the exact timeline remains uncertain.
What Happened
The ruling determined the tariffs were unlawful, but it did not automatically trigger refunds. A separate administrative process must be created before any claims can be filed or payments issued. Public reporting indicates that U.S. Customs and Border Protection collected roughly $166 billion in duties across the affected entries.
Shortly after the ruling, the administration terminated the IEEPA tariffs and replaced them with a temporary 10 percent import surcharge under Section 122 of the Trade Act of 1974. The Court of International Trade initially ordered CBP to begin issuing refunds, but that order was suspended after CBP explained that its systems could not handle refunds at the scale required. As a result, the federal government is now developing a new process for submitting and reviewing claims.
Who Receives the Refunds and How It Will Flow
This is the most important point to understand. Under U.S. customs law, refunds are issued to the Importer of Record listed on the customs entry. They are not issued to downstream buyers.
- Royal Coffee, as the importer, paid duties directly to the U.S. government when coffee entered the country.
- Those costs were reflected in coffee pricing during the tariff period.
- If refunds are issued, they will first be paid to Royal Coffee through CBP.
- Importers then determine how those funds should be reconciled with affected customers.
Royal Coffee is identifying which entries may be affected and reviewing how duties were reflected in pricing during the relevant period.
Once the government refund process is operational and we know what refunds Royal Coffee actually receives, we will communicate our approach to reconciliation.
We are not in a position to make commitments before the government process is finalized, but customers will receive a clear answer once the scope of refunds becomes known.
Where the Government Process Stands
Refunds are not yet being issued. According to court filings and public reporting, CBP is developing a new system called Consolidated Administration and Processing of Entries (CAPE) within its Automated Commercial Environment platform. This system will allow importers to identify affected entries, submit claims, and receive electronic refunds through the U.S. Treasury.
As of March 12, 2026, CBP reported the system was more than 40 percent complete, with a target launch window in mid-to-late April. However, that timeline is an estimate rather than a court deadline. Even once the system opens, processing refunds across millions of entries could take considerable time. Trade analysts across several industries expect the refund process to unfold over months rather than weeks.
Trade counsel across several industries have also noted that the government could still challenge aspects of the refund process, and that certain technical arguments could limit eligibility for some entries. The Court of International Trade continues to oversee implementation, and additional rulings are possible.
A Common Misunderstanding
Some recent news coverage has created the impression that tariff refunds are already available. That is not the case. The federal government has not yet opened the claims system required to process refunds. Until that system exists, no importer in any industry can submit refund claims or receive payments.
Additionally, the Supreme Court ruling applies only to tariffs imposed under IEEPA. Tariffs imposed under other legal authorities are not affected by the ruling and are not subject to this refund process.
What This Means for Roasters Right Now
- At the moment there is nothing roasters need to file or submit.
- Refund claims must be filed by the Importer of Record, which means the filing process will be handled by importers once CBP opens the system.
- Royal Coffee is already reviewing affected entry records with our customs brokers so we can submit claims as soon as the filing process becomes available.
- Until the government system opens, the industry is waiting.
What Royal Coffee Is Doing Right Now
Even though the claims system is not yet available, we are preparing for it. Our logistics team and customs brokers are taking the steps required under U.S. customs procedures to preserve eligibility for potential refunds.
- Maintaining entries within the applicable liquidation window.
- Filing protests where necessary to preserve refund eligibility.
- Completing the registration required to receive electronic refunds from CBP.
Our goal is to be ready to file claims as soon as the federal process opens.
A Note on Green Coffee and Section 122
Following the Supreme Court ruling, the administration imposed a temporary 10 percent import surcharge under Section 122 of the Trade Act of 1974. Green coffee is explicitly excluded. The exemption list includes:
HTS 0901.12.00 — coffee, not roasted, decaffeinated
If you are purchasing green coffee from Royal Coffee, no Section 122 surcharge is being added to your cost.
What Happens Next
CBP still needs to finalize the systems and procedures required to process refund claims. Once the filing system opens, importers will be able to submit affected entries for review. We will continue monitoring CBP guidance and working with our customs brokers so we are ready to act when the process becomes available. We will share updates with customers as new information develops.
Final Note
Tariff policy often moves quickly while the legal and administrative processes that follow move more slowly. The coffee industry is now in that second phase. There is real potential for refunds tied to the IEEPA tariffs, and there is also real potential for further litigation and delays. The systems required to process those refunds are still being built, and the exact mechanics are not yet finalized.
Royal Coffee is working closely with our customs brokers and monitoring developments across the trade and legal landscape so we are prepared to act when the government process becomes available. As the situation evolves, we will continue sharing updates so customers have a clear understanding of what is happening and what it means for their business.
Tariff Refund FAQ for Roasters
Are tariff refunds available right now?
No. The U.S. government has not begun issuing refunds related to duties collected under the IEEPA tariff program. The Supreme Court established that the duties were unlawfully collected, but the administrative system required to process refund claims is still being developed by CBP.
Who receives the refund if tariffs are returned?
Refunds are issued to the Importer of Record listed on the customs entry. For green coffee shipments, this is typically the importer such as Royal Coffee, since the importer pays duties directly to the federal government when goods enter the United States.
Can roasters apply for refunds directly?
No. Because roasters are not the importer of record on the customs entry, they cannot apply for tariff refunds directly through CBP. Any refund would first be issued to the importer, who would then determine how those funds should be reconciled with customers.
If tariff costs were reflected in coffee pricing, will roasters receive refunds?
If refunds are ultimately issued by the government, they will first be paid to the importer through CBP. Importers will then review the relevant entries and communicate with customers about how reconciliation will occur. Because refunds have not yet been issued, it is too early to determine exactly how or when that reconciliation may take place.
Should I submit documentation or invoices now?
Roasters do not need to file anything with CBP. That process runs through the importer of record. However, if tariff costs were absorbed in your business rather than passed to your customers, it is worth keeping records of your purchases and pricing during the relevant period. That documentation will be useful when we work through reconciliation.
How long could refunds take?
Even after the claims system opens, processing refunds across millions of import entries could take considerable time. Many trade analysts expect the process to unfold over months rather than weeks.
When will we know more?
The industry is currently waiting for CBP to finalize the systems required to process refund claims. Royal Coffee will continue monitoring developments and share updates as more information becomes available. If you have questions about a specific contract or shipment, please reach out to your Royal Coffee trader directly.
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