By: Sara E. Yood, Esq.,  Jewelers Vigilance Committee

Tariffs continue to be a central feature of the Trump Administration, and form the basis of its trade policy. The broad brush used by the administration has affected everyone in every market. For some US-based producers, businesses shifting casting production to the US has been a significant benefit over the last year. For others, facing the challenges of import duties on products that previously came in at 0% has led to a fundamental shift in liquidity. Following the constant changes can be challenging, but  the Jewelers Vigilance Committee provides consolidated and clear guidance that can help you proceed.

In late February, the Supreme Court overturned the president’s tariffs enacted under IEEPA (International Emergency Economic Powers Act) – this includes the “border crisis” tariffs, the “fentanyl crisis” tariffs, the “reciprocal” tariffs – and ordered the Court of International Trade (CIT) to handle the refund process. Since then, CIT has been holding hearings with Customs & Border Protection (CBP), the agency tasked with collecting – and refunding – tariffs.

CBP opened Phase One of its Consolidated Administration and Processing of Entries (CAPE) portal in the Automated Customs Environment (ACE) system to apply for tariff refunds in late April. Only companies that are the Importer of Record (IoR) on an entry may submit the request for a refund. An entry is one import that was recorded with Customs. Phase One entries that are eligible for a refund include entries that are unliquidated (aka where the final tariff calculation has not been confirmed by CBP – usually entries liquidate at 314 days) or anything within 80 days of liquidation. Most of the IEEPA tariff entries are still within this phase but some older entries may be beyond this time period and have to wait.

If you paid tariffs on entries between February 2025 (when the administration first levied the varying rates on Mexico, Canada, and China) and February 2026 (when the Supreme Court overturned these tariffs) you are likely eligible to apply for a refund. There are very detailed instructions on how to apply through CAPE on the Customs website here: https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds. Regular tariffs paid outside of the IEEPA tariffs (such as the previous Section 301 China tariffs, or the new Section 122 10% global tariffs) are not eligible for refunds. These payments will be refunded to importers with an additional 6% in interest (as is standard with government refunds.)

Since the overturning of the IEEPA tariffs, the Trump administration has pushed to replace them with tariffs using other authority. The Section 122 10% tariffs that were enacted to address “balance of payments” issues will expire by July 24. The administration, however, is pursuing other tariffs under Section 301 and holding hearings to determine whether these are necessary. Many entities and individuals have already provided testimony for and against these tariffs. It is likely that the outcome of the hearings will be very similar rates to the IEEPA tariffs levied on over 60 different countries. It is also expected that these hearings and determinations will conclude in advance of July 24, and that global tariff rates will once again increase significantly. The trade deals that the US had previously negotiated with various countries would then come back into play, meaning that for countries that had already negotiated, their rates are likely to be similar under the 301 authority.

JVC recommends that businesses file for refunds of duties owed expeditiously, especially considering that the rates are expected to rise again. The current tariff rates are tracked at JVC’s Tariff Tracker, which is generously funded by the JCK Industry Fund. Additional questions can be directed to the JVC legal team at info@jvclegal.org.