Your IEEPA refund came in. Now work out what each customer is owed, invoice by invoice.
We build the tool that matches your refunded entries to the tariff surcharge lines you billed, applies the rules from your own contracts, and prints a credit note for each customer. The same data then drives tariff-aware quotes and price lists.
From refund to credit note
- Refunds matched to invoicesBy entry number, PO or SKU, from data you already have
- Your contract rulesFull, partial or no pass-through per customer, set by you
- Credit notes and an audit trailA PDF per customer and a log of every figure
On 20 February 2026 the US Supreme Court ruled in Learning Resources, Inc. v. Trump that IEEPA does not let the President impose tariffs. CBP now pays the refunds through CAPE, a tool in ACE. The money goes to the importer of record, with interest.
Many distributors, wholesalers and manufacturers passed those duties on as a "tariff surcharge" line on their invoices. Now customers are asking for their share. Some consumers have already sued Costco and FedEx over it. To answer a customer, you need to know which of their invoices carried which duty, from which entry, and what your contract says.
Krira Digital is a small software studio in India. We build that calculation for you as a web app, using your own invoice data and your own rules. We work with US companies remotely, with calls in your morning.
- Supreme Court ruling, 20 Feb 2026
- Learning Resources, Inc. v. Trump (PDF)
- Refund process and CAPE rules
- CBP: IEEPA duty refunds
- Refunds certified, mid-Sep 2026
- About $122 billion (C.H. Robinson, citing CBP)
- CAPE Phase 3, 6 Oct 2026
- Finally liquidated entries (Phillips Lytle)
- Importer class certified, 8 Oct 2026
- Court of International Trade (Thomson Reuters)
- Customer lawsuits
- Costco and FedEx sued (Fortune)
- Section 301 duties from 24 Jul 2026
- 10% or 12.5% on 60 economies (EY)
- Cabinets and vanities, 1 Jan 2027
- Section 232 rate to 50% (Federal Register)
Where IEEPA refunds stand in November 2026
CAPE opened in phases. Phase 1 (20 April 2026) took unliquidated entries and entries within 80 days of liquidation. Phase 2 (29 June 2026) added entries flagged for reconciliation. Phase 3 (6 October 2026) covers finally liquidated entries, but for now only for importers that have their own case at the Court of International Trade and a court order to reliquidate.
Only the importer of record or the licensed customs broker who filed the entries can file a CAPE declaration. The file lists entry numbers only, 11 characters with no dashes, up to 9,999 per declaration. Interest is included in the refund. CBP says most refunds reach the ACH account 3 to 5 weeks after liquidation.
On 8 October 2026 the Court of International Trade certified a class of importers that paid IEEPA duties between 1 February 2025 and 19 February 2026 and did not sue on their own. That does not pay anyone yet, and the government can appeal. By mid-September about $122 billion had been certified for payment, so a lot of money is landing in year-end books.
Those are the importer's steps. This page is about the next one: what you owe the customers you billed.
Why the refund is hard to pass on
What we build
Partial refunds, interest and Phase 3 entries
The tool tracks refund status per entry: claimed, certified, paid or on hold. A customer's share is only released when the money behind it has arrived, if that is your rule. When only part of an entry is refunded, the share is split across the invoice lines in the same proportion.
Interest is a separate column. Whether you pass it on is a rule you choose with your counsel. Finally liquidated entries that wait on a court order stay in a "pending" bucket, so you can tell a customer exactly which invoices are still open.
If a customer or a class action challenges your numbers
You need to show your work. Every credit note links back to the invoice lines, the entries and the rule that produced it. Imports are kept as uploaded. Rule changes are dated and signed by a user. You can export the full trail for your lawyer or auditor as a spreadsheet.
We do not decide who is owed what. Your contracts, your counsel and the courts decide that. The tool makes sure the math matches the rules you set, every time, for every customer.
Surcharge line or price increase?
| Separate surcharge line | Built into the price | |
|---|---|---|
| When duties change | Change one rate; the line updates on new quotes and invoices | Re-price every SKU and re-issue every list |
| When duties are refunded | You can show each customer exactly what they paid | Hard to prove what part of the price was duty |
| Customer view | Clear, but customers may ask for it back | Simple, but harder to explain later |
| What to record on the line | Rate, basis, HTS code, country of origin and the tariff program | Nothing separate; keep your cost build-up on file |
Which one suits you depends on your contracts and your market. Ask your counsel which wording to use on invoices and quotes.
Re-pricing when duty rates change again
Rates moved three times in 2026. The IEEPA duties ended in February. A temporary Section 122 surcharge ran until 24 July. Since 24 July, Section 301 duties of 10% or 12.5% apply to goods from 60 economies, on top of normal (MFN) duty. Goods already under a Section 232 tariff are excluded from these Section 301 duties. The Section 301 duties are being challenged in court, so more change is possible.
The quote side of the tool keeps a SKU table with country of origin and HTS code, and a rate table your broker or buyer updates once. New quotes get the right surcharge line. Price lists can be re-issued in bulk as PDFs, with a price-change letter to each customer by email. Every quote carries an expiry date and the rates it was priced with, so a quote sent before a change stays honest.
Half your catalog not classified yet? The tool flags SKUs with no HTS code or origin and keeps them on a to-do list for your broker. We don't classify goods ourselves.
Cabinet and vanity sellers: the 1 January 2027 change
| Today | From 1 January 2027 (scheduled) | |
|---|---|---|
| Kitchen cabinets and vanities | 25% Section 232 duty | 50% |
| Upholstered wood furniture | 25% | 30% |
| Countries with a deal | Their agreed rate | The increase does not apply to countries that reach an agreement |
| Your open quotes | Priced at today's rate | Need an expiry date or a tariff clause before 1 January |
Source: Proclamation 11000 of 31 December 2025, published in the Federal Register on 9 January 2026. It moved the increase from 2026 to 2027. Check the Federal Register or your broker before you rely on the date.
A price book for cabinet and vanity dealers
What we have built before, and what is new
We have not built a tariff refund tool for a client yet, and we won't pretend we have. The parts are not new to us. For a window fabricator we built quoting software that prices from the shop's own Excel rate formulas, prints the quotation, sends it as a PDF and turns it into an invoice. For a school we replaced an Excel workbook of fees and receipts with an app that issues receipts and keeps every payment on record.
A refund allocation tool uses the same pieces: import rows, apply rules, show a person the result, print the document and keep a log. The stack is Postgres, so 100,000 or more invoice lines are not a problem.
How a build runs
- 1Send sample dataAn ACE refund report or entry list, one month of invoice lines, and two or three customer contracts or surcharge notices. Dummy names are fine.
- 2Rules and a test runYou write down the pass-through rules with your counsel. We code them and run your sample. You check the totals against your own spreadsheet.
- 3Full import and go-liveWe load all entries and invoices, your team approves the first credit notes, and we hand over the app, the code and the logins.
What we are not
Krira Digital is not a customs broker or a law firm. We don't file CAPE declarations, don't talk to CBP for you and don't give legal or tax advice on who is owed what. Your broker files the claim. Your counsel sets the rules. We build the calculation and the paperwork from those rules and your own data. Matching quality depends on your data: we can only use entry numbers, PO links or SKUs that already exist in your records.
Questions
Do I have to pass tariff refunds on to my customers?
It depends on your contracts and how you billed. An explicit surcharge line plus a clause that adjusts it when duties change gives customers the strongest claim; a fixed price that said nothing about duties gives the weakest. Ask your counsel. We build the tool that applies whatever rules you settle on.
How do I match IEEPA refunds to the invoices that had a tariff surcharge?
Start with the links your data already has: entry number on the receipt, PO, SKU or lot. The tool imports your ACE refund report and invoice lines, matches them on those keys and lists anything it cannot match. Where stock from several entries was mixed, it splits by the rule you choose, such as first in, first out.
Who can file a CAPE declaration for IEEPA refunds?
Only the importer of record or the licensed customs broker who filed the entries, per CBP. Attorneys cannot file on an importer's behalf. The file holds entry numbers only, 11 characters without dashes, up to 9,999 per declaration. We don't file CAPE declarations.
What if we charged a flat percentage tariff surcharge instead of the actual duty?
Then the customer's share is not simply the surcharge they paid. The tool can work it out both ways: by the surcharge billed, or by the real duty on each SKU from the entry. Your counsel decides which one your contracts support, and the tool applies it to every invoice.
Should we issue a credit note or a cash refund for a tariff surcharge?
Many distributors use credit notes for active accounts and cash refunds for closed ones. The tool can do both, per customer, and exports the result for your books. The choice is a business and legal one for you and your counsel.
Is a tariff surcharge taxable?
It depends on the state. Some states treat a surcharge on a taxable sale as part of the price, so sales tax applies to it. Ask your tax adviser. The tool keeps the tax on each surcharge as its own figure, so a credit note can reverse it in the same proportion.
Should a tariff be a separate line on the invoice or built into the price?
A separate line is easier to change when rates move and easier to prove if duties are refunded. Built-in pricing is simpler for customers but harder to unpick later. Record the rate, basis, HTS code and origin on the line if you keep it separate.
Can it work with QuickBooks, NetSuite or Excel?
Yes. It reads exports from QuickBooks, NetSuite, other ERPs or Excel, and writes credit notes back as CSV your system can import. It sits beside your accounting system and does not replace it. For quoting, see our Excel quote calculator to quoting tool page.
How long does it take, and what does it cost?
It depends on how clean your data is and how many contract types you have. The first test run on your sample data is the slowest step, because that is where the rules get settled. We put the delivery date in your written quote.
We did not find any public price list for this kind of tool: brokers and law firms price the importer's claim, not the customer pass-through. Compared with Excel, you pay once for the build and then hosting, and you get a tool that gives the same answer every time and keeps a record. We quote a fixed price after one call and a look at your sample data.
A fixed quote after one call
Send a sample of your refund data, invoice lines and contract terms, with dummy names if you prefer. After a short call we reply with a fixed price and a delivery date in writing. Payment in stages.
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