For CFOs today, an estimated $166 billion in tariff refunds is at stake, but that process likely won’t be seamless.

Following the Supreme Court's February 2026 decision striking down IEEPA tariffs, U.S. Customs and Border Protection is building a claims process that could return that sum to importers. The system is expected to run through the existing ACE platform, with companies submitting detailed entry data and supporting documentation before refunds are issued. The claims portal could open as early as mid-April, though when payments arrive is another question.

For manufacturing CFOs, the basic proposition is straightforward: Refunds are coming, but they will depend on the quality and traceability of historical data. What's less obvious is how difficult that reconstruction effort may be.

In many organizations, tariff costs didn't stay neatly contained within import records. They were absorbed into operations over time, as finance teams worked alongside supply chain and procurement to manage rising costs as they occurred. Those decisions now have to be unwound.

At the front end, the task looks manageable. Companies can identify shipments subject to IEEPA tariffs, confirm importer-of-record status, and gather payment records. This aligns with early CBP guidance, which emphasizes accurate import declarations and clear documentation tied to each entry. Most of this information exists, even if it's scattered across systems.

The challenge begins once those costs move beyond the border.

Tariffs were typically incorporated into inventory values and eventually into the cost of goods sold. Manufacturers would spread a single tariff event across a wide range of products. A $100,000 tariff applied to one container could be distributed across 200 to 500 SKUs, each following a different production timeline and pricing path. Costing methods varied by business unit, which added another layer of variation.

That distribution makes it hard to trace the original tariff burden. Finance teams must determine how much of a given tariff payment was allocated to each product, and when that impact was recognized. In many cases, those products have already been sold or phased out. The original cost signal becomes harder to isolate with each step.

Pricing decisions add another dimension. Many manufacturers adjusted prices, or renegotiated terms with customers. Others absorbed the impact to protect volume, often without clarity on how long tariffs would remain in place. The financial effects extend well beyond the duty payments themselves: Some companies saw volume shift as customers reacted to higher prices, and others experienced margin compression while holding sales levels. In either case, the effect shows up in the business in ways that don't map cleanly back to the original import entry.

This raises a more technical question for CFOs: To what extent were those costs ultimately borne by the company, rather than passed through to customers? Depending on how refund frameworks are applied, this distinction may influence eligibility, or require additional support. In practice, that means companies will need to substantiate how pricing decisions were made, using margin analysis, contract terms and historical pricing data to demonstrate where the economic burden actually sat.

A Matter of Interpretation

How those costs flowed through the business now becomes critical. If tariffs were built into pricing, companies would need to decide how to treat recovered funds. That includes evaluating whether any portion of those costs had already been passed through to customers, which may affect how claims are supported and how results are interpreted internally.

There are also downstream financial implications to consider. Refunds may carry tax consequences depending on how the original tariff costs were treated, and finance teams will need to assess whether prior deductions or reporting positions are impacted. For companies with inventory still on hand, previously capitalized tariff costs may also need to be revisited, potentially requiring adjustments to product costing and future margins.

Timing creates its own complications. Tariffs were typically incurred at import but recognized over time as inventory moved through production and into sales. Refunds, by contrast, are expected to arrive in concentrated amounts tied to historical entries, with delays likely, given that the claims infrastructure is still under development. The mismatch between when costs were recognized and when cash arrives will require careful attention in both reporting and planning. Companies that have navigated multiple rounds of tariff changes face overlapping impacts from different periods.

The policy environment makes this harder still. New tariffs and reciprocal measures are still weighing on sourcing decisions. Manufacturers are dealing with current cost pressures while simultaneously preparing to recover past payments. The same data being assembled for refund claims can support scenario modeling for future tariff exposure, but only if that underlying information is consistent and organized enough to actually use.

It will take every corner of your business to get ready for tariff refunds. Finance depends on the supply chain department for shipment data and sourcing context. Procurement can clarify how costs were handled at the supplier level. Commercial teams can explain how pricing changes affected demand. Bringing those perspectives together produces a better foundation for responding when refunds are issued and when policy shifts again.

From a practical standpoint, CFOs should focus on building a clear audit trail, from import entry to financial outcome. That includes linking tariff payments to specific shipments, connecting those shipments to inventory records, and tracing how costs appeared in product-level results. When gaps exist, teams may need to reconstruct information based on documented assumptions.

System readiness matters too. The expected claims process will rely on ACE accounts and structured data submissions, including bulk uploads of entry information. Ensuring accounts are current, and data can be extracted in the required format will reduce friction once the portal opens.

It’s hard to overstate the scale of the effort this will take. You probably won’t get it right on the first try, either. Early submissions may need adjustment. Companies that were fastidious about their data before the tariffs will have an advantage over those that were not. But for now, the immediate task is documenting what was paid. The deeper task is understanding how those tariffs moved through pricing and margins. 

Bryan Graiff is Midwest industry leader, manufacturing & distribution leader at Armanino, and Nghi Huynh is partner-in-charge, transfer pricing at Armanino.