Date:2026-05-14
The U.S. Customs and Border Protection (CBP) officially announced on May 12 that, as of May 11, it has processed tariff refunds (including interest) amounting to as much as $35.46 billion, with the first batch of funds gradually being transferred to the bank accounts of foreign trade merchants. These refunds mainly target tariffs imposed last year under the Trump administration pursuant to the International Emergency Economic Powers Act (IEEPA), which were subsequently ruled 'illegal' by the U.S. Supreme Court, including the controversial 'reciprocal tariffs' and 'fentanyl tariffs.'
According to a statement submitted by CBP officials to the U.S. Court of International Trade, as of the morning of May 11, CBP had received 126,237 tariff refund applications and verified 86,874 of them, covering 15.1 million import records eligible for refunds. Although about 15% of the applications were rejected due to incorrect information or non-compliant goods, refunds for 8.3 million shipments have already been calculated. Citibank analysts pointed out that major retailers such as Walmart, Target, and Nike are expected to receive tens of billions to over one hundred billion dollars in substantial tax refunds, while manufacturing giants like General Motors will also benefit significantly.
The total amount of this tariff refund is expected to reach as high as $166 billion, involving approximately 330,000 importers and over 53 million imported items, most of which stem from tariffs imposed on Chinese goods. However, whether Chinese exporters can benefit from it entirely depends on their trade models and contract terms, as refunds strictly follow the principle of 'whoever pays the tariff gets the refund,' and the direct recipient must be a 'registered importer' (IOR) filed with U.S. Customs.
Specifically, Chinese exporters face four distinctly different scenarios:
U.S. Subsidiary Model: If a Chinese company has a subsidiary in the U.S. and the subsidiary acts as the importer for customs clearance and duty payment, the refund can be directly applied for through the U.S. subsidiary, which is the most straightforward path.
DDP (Delivered Duty Paid) Model: The Chinese exporter is responsible for shipping goods to a designated location in the U.S. and handling customs declaration and duty payment. In this model, the Chinese exporter can apply for a refund as the importer, but the contract terms must be clearly specified.
FOB or CIF Model: This is the most common export model for China. Although duties are nominally paid by U.S. customers, many tariff costs have actually been passed onto Chinese exporters through price reductions or discounts. Companies under this model need to proactively negotiate with U.S. buyers to share refund benefits or secure better pricing for new orders.
"Tax-Cleared" Model: The Chinese exporter pays the tariff, but the legal importer is a freight forwarder or logistics company. In this case, refunds can only be negotiated with the partner, and success largely depends on the partner's willingness to cooperate.
Additionally, for parcels shipped directly via international logistics companies like UPS, FedEx, and DHL, these companies have explicitly stated that they will refund the charges directly to customers affected by the IEEPA tariffs.
The U.S. refund process relies on the "Customs Unified Management and Processing Tool" (CAPE) system, launched on April 20. Importers need to submit declarations through the CBP online portal and provide ACE accounts and bank information. The CAPE system uses a phased refund strategy: the first phase prioritizes the processing of customs records that have not yet been finally cleared and those within 80 days after clearance, covering approximately 63% of refunds; subsequent phases will gradually handle records cleared for more than 80 days, anti-dumping/anti-subsidy cases, bonded warehousing, and other complex situations.
Although the Supreme Court has ruled the Trump tariffs invalid, the uncertainty of trade policy has not disappeared. Following the February ruling this year, the Trump administration quickly shifted and imposed a temporary 10% tariff on global goods under Section 122 of the Trade Act of 1974. Although the U.S. Court of International Trade ruled this temporary tariff illegal last week (May 7), the ruling currently applies only to a few companies as plaintiffs and to the state of Washington. The Trump administration promptly filed an appeal, and an appellate court temporarily stayed the adverse ruling on May 12, meaning that the global temporary tariffs are still in effect.
It is worth noting that although ordinary consumers spent an average of about $700 more per household in 2025 due to IEEPA tariffs, they will not directly receive refunds. Many companies receiving refunds indicated that they will use the funds to repay debts, hire employees, replenish inventory, or lower product prices, rather than directly compensating consumers.
For global trade, this refund is not only a belated corporate "lifeline" but also a profound reminder for future supply chain compliance and contract design. In the face of high-frequency fluctuations in U.S. trade policy, Chinese enterprises must explicitly stipulate in future cross-border trade agreements the party responsible for tariffs and the allocation of refund proceeds, to prevent policy risks from the outset.
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