Editorial Team It’s a dangerous fantasy to think a business can just eat the cost of shifting trade policy, especially when it comes to IEEPA refunds, and not have it ripple through their entire pricing structure. It’s 2026. The global economy is too volatile for that kind of static, set-it-and-forget-it thinking. If your company isn’t building potential refunds and tariff swings into its core pricing strategy, you’re not just leaving money on the table. You’re actively burning cash on duties you could get back, which bloats your cost of goods and makes your products more expensive than a competitor who’s on top of their game.
Key Takeaways
- Go after IEEPA refunds. They’re not pocket change. We’re talking about a piece of the billions in tariffs returned to U.S. businesses, and that cash directly lowers your net landed cost.
- Build potential tariff changes and refund mechanisms into your pricing models from day one. This gives you a true cost of goods, not one based on a tariff that might get refunded later.
- Set up a clear internal process for who tracks duties and who files refund claims. Without a system where compliance flags an opportunity and finance models the cash flow, you’re guaranteed to leave eligible money with the government.
- Get your trade counsel and customs brokers involved early. A sharp broker might spot that a new OFAC general license applies to a component you’ve been paying a tariff on for two years, unlocking a significant refund.
- A flexible pricing strategy that bakes in trade policy shifts is how you protect your margins and stay competitive, because it lets you adjust faster than rivals when costs suddenly drop.
Your Costing Model is Dangerously Outdated
For too long, companies have treated import duties and potential refunds like an accounting cleanup job, totally separate from the rest of the business. That thinking is a relic. The reality of global trade today, with its sudden IEEPA sanctions and whiplash-inducing policy changes, requires you to connect the dots. Think about it: when sanctions trigger tariffs, you pay them. But when those sanctions get tweaked or an exclusion is granted, a refund opportunity opens up. These refunds can be substantial. A manufacturer importing a specialized alloy might have paid millions in tariffs over a couple of years. If that sanction gets amended, those millions become refundable. The problem is, most companies just bake the tariff into their cost of goods sold, raise prices, and move on, with no real system to claw that money back. So if you price a product based on a landed cost that includes a tariff you later get refunded, you’ve either overcharged your customers or you’ve just been sitting on inflated margins for no strategic reason. A smarter way is to build a pricing model that expects this stuff. It’s risk management and opportunity capture. A 2024 U.S. International Trade Commission (USITC) report showed that tariff relief programs have sent billions of dollars back to U.S. businesses over the last five years, but a huge chunk of that money is never claimed because companies either don’t know it exists or can’t handle the paperwork. That’s cash that goes directly to the bottom line.
Baking Refund Potential Into Your Pricing Strategy
Potential IEEPA refunds and other tariff adjustments have to be a direct input into your supply chain pricing strategy. This means finance, procurement, and sales can’t operate in their own worlds anymore. When procurement is negotiating with a supplier in a region known for trade policy swings, they need to be talking about the Harmonized Tariff Schedule (HTS) codes and potential for refunds, not just the unit price. They need to be watching Treasury and Commerce Department announcements like a hawk and keeping perfect records of every duty payment. Imagine you import a critical polymer from a country under IEEPA sanctions. Your initial pricing includes the tariff. But then the government issues an exclusion for that specific material. If your pricing is rigid, you’re stuck, either you keep your prices high and lose to a competitor who adjusted, or you have a fire sale that makes you look unstable. The proactive approach is to build a “tariff contingency” into your model. Maybe you price your product with a 5% tariff buffer but you are simultaneously filing the paperwork for a refund on that tariff. When the refund comes in, you can strategically use that 5%: a piece to lower customer prices, a piece to R&D, and a piece to your own profit margin. This is strategic financial management.
The Nitty-Gritty: How to Actually Track and Claim Refunds
Having a dynamic pricing strategy is one thing, but making it work requires real operational discipline. You have to build a system to actively track, claim, and communicate these financial events. This means:
- Dedicated Compliance People: You need someone (or a team) whose job is to read Office of Foreign Assets Control (OFAC) and Customs and Border Protection (CBP) announcements every day and match new rulings against your company’s HTS codes. These people need to know IEEPA inside and out.
- Careful Record Keeping: Every single import entry, tariff payment, and email with customs has to be documented. If you can’t produce the evidence, your claim, no matter how legitimate, is likely dead on arrival.
- Working with Brokers and Counsel: Outside experts are not a luxury. A good customs broker lives and breathes this stuff and can spot an opportunity you’d miss, while trade counsel provides the legal muscle to make your claim stick. I’ve seen a client in the electronics sector get back over a million dollars on components because their trade counsel successfully argued a specific IEEPA exclusion applied to their HTS code, a claim that would have failed without that legal backup.
- Clear Internal Communication: There has to be a clear protocol. When your legal team identifies a potential refund, they must have a way to immediately tell the finance team to adjust cash flow forecasts and the sales team to re-evaluate pricing against competitors.
Some will say the administrative hassle isn’t worth it for a small business. That view completely misses the point. Leaving a potential 5% refund on the table for a product line with $20M in imports means you’re burning $1M that your competitor might be putting back into their business. Plus, tools like Descartes CustomsInfo can automate a lot of the tracking, giving you real-time updates on tariff classifications. Complaints about administrative burden are often just an excuse for organizational inertia, a refusal to deal with how global trade actually works now.
Using Tariff Refunds to Outmaneuver Competitors
In the end, building IEEPA refunds into your pricing is about creating resilience and a real competitive advantage. In a market this tight, ignoring potential capital recovery is just bad business. Companies that can accurately forecast their net landed costs, including those potential refunds, are the ones making smarter decisions on everything from sourcing to inventory. They can move faster. Think about two companies, A and B, selling the same widget. Company A prices based on the gross tariff cost and only reacts when a refund check (maybe) shows up months later. Company B, however, has a flexible pricing model that anticipates the refund and actively chases it. When that big IEEPA refund comes through, Company B can immediately drop its price by a few points to steal market share while Company A is still playing catch-up, their prices stuck reflecting a cost they no longer have. This is about strategic survival. You can’t treat trade policy as some static, external factor anymore. IEEPA refunds and other tariff adjustments are part of your true landed cost, and they belong in your supply chain pricing strategy. Failing to do this is a fundamental miscalculation that will chew away at your profitability and competitiveness in the global market of 2026 and beyond. You have to invest in the people and systems to manage these complex financial flows, turning tariff liabilities into strategic assets for your balance sheet and your market position.
What is IEEPA and how does it relate to trade policy?
The International Emergency Economic Powers Act (IEEPA) is the law giving the U.S. President power to control international trade when there’s a national emergency. It’s often used to impose sanctions, which can mean slapping tariffs on goods from certain countries. These tariffs hit your import costs and have to be factored into your pricing.
How can IEEPA refunds impact a company’s pricing strategy?
Securing a refund means your true cost of goods is lower than you originally calculated, sometimes long after the sale. This gives you options: you can use that recovered cash to lower prices and gain market share, hold prices steady and boost your margins, or reinvest the windfall into the business.
What steps should businesses take to claim IEEPA refunds?
First, you need careful records of all your import entries and every dollar you’ve paid in duties. Then, you have to constantly monitor announcements from government agencies like OFAC and CBP for changes. Finally, you need to work with your customs broker or trade lawyer to prepare and file the actual claim. Documentation is everything.
Is it worth the effort for smaller businesses to pursue IEEPA refunds?
Yes. The capital you recover can be a big deal even for a smaller company, particularly if you import high-value or high-volume goods. The long-term benefit of setting up a good compliance process is that you stop overpaying on duties in the first place, which makes your business more financially nimble.
How can technology assist in managing trade policy impacts and refunds?
ERP systems and specialized trade compliance software, like Descartes CustomsInfo for example, can automate a lot of the grunt work. They can track all your HTS codes, monitor tariff rates, and send alerts on regulatory changes in real-time, essentially flagging potential refund opportunities that a person might miss.
