Do You Qualify for a Tariff Refund? The Importer of Record Test

There are a lot of factors that affect how much you can recover in tariffs, but only one that decides whether you can recover at all: were you the importer of record? Everything else follows from that.

What importer of record means

The importer of record is the party legally responsible for a customs entry and the duties on it. It is the business whose name is on the entry and that paid CBP directly. That party, and only that party, is positioned to claim a refund on those duties.

Why pass-through cost payers do not qualify

Tariffs raise prices throughout the supply chain. If you bought goods from a distributor and paid more because of tariffs, you felt the cost, but you were not the importer of record. In that case the importer you bought from is the one who can file. You are a pass-through cost payer, not the filing party.

The rest of the eligibility picture

If you were the importer of record, a few more things make a strong case: entries in 2025 or 2026, duties that likely include Section 301 or IEEPA tariffs, and no formal duty-recovery review in the recent past. An active ACE Portal account is required to file, but if you do not have one, that is fixable.

The fastest way to know

You do not have to work this out on your own. A free eligibility check runs through these questions in about a minute and tells you whether your entries are likely to qualify. If they are, we connect you with specialists who take it from there.