A long-awaited tariff refund process begins Monday in the United States, potentially unlocking more than US$160 billion in repayments for importers ranging from major retailers such as Walmart and Target to smaller businesses, following a Supreme Court ruling that invalidated earlier emergency tariff measures.
U.S. Customs and Border Protection (CBP) is launching a new digital claims system, known as the Consolidated Administration and Processing of Entries (CAPE), which will allow companies to file for refunds on tariffs paid under what the court ruled to be an unlawful use of emergency trade authority.
Officials say importers will be able to submit claims through the portal and receive a consolidated refund after validation. However, trade lawyers and analysts warn that the process is likely to be slow, complex and subject to administrative and legal hurdles.
“There’s frustration because the Supreme Court already ruled that these tariffs are unlawful,” said Matthew Seligman, a trade attorney at Grayhawk Law, adding that companies expect the government to make recovery of funds difficult.
Despite the optimism surrounding the launch, expectations remain tempered. Stefan Reisinger, a partner at Norton Rose Fulbright, said companies are doubtful the system will function as smoothly as described.
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“There’s a fair degree of pessimism in the importing community about whether this is really going to work the way it’s described,” he said.
The scale of potential refunds is significant. According to Citi research, Walmart could be due about $10.2 billion, Target $2.2 billion, Nike $1 billion, Kohl’s $550 million, Home Depot $540 million, Gap $400 million, and Macy’s $320 million. The estimates reflect tariffs paid under now-invalidated policies affecting a wide range of imported goods.
While the refunds could provide a one-time boost to corporate balance sheets, analysts say they are unlikely to materially affect forward-looking earnings forecasts. Instead, companies are expected to weigh options such as debt reduction, share buybacks or strengthening cash reserves.
Walmart Chief Financial Officer John David Rainey said the process is expected to take time due to its complexity.
“It would seem to be very complex and, by extension, probably not something that’s going to happen very quickly,” he said at a recent investor event, adding that the company would pursue refunds but had no timeline for receipt.
If and when refunds are issued, accounting rules suggest they would be reflected as a positive impact in corporate earnings statements.
However, the potential windfall also carries legal uncertainty. Trade lawyers warn that companies could face litigation risks if they reclaim tariffs that were previously passed on to consumers through higher prices.
A January study from Harvard Business School’s Pricing Lab estimated that tariff pass-through contributed roughly 0.76 percentage points to U.S. inflation through October 2025, indicating that consumers bore part of the cost.
“If [companies] get refunds, what are the chances that they’re going to get sued either by direct or indirect customers?” Reisinger said, highlighting possible downstream disputes over recovered funds.
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The policy environment remains fluid. U.S. officials have signaled that although the Supreme Court ruling invalidated the prior tariff mechanism, alternative trade tools remain under consideration, including Section 301 tariffs, which target unfair trade practices.
Treasury Secretary Scott Bessent recently suggested that tariff levels could be reinstated through such mechanisms as early as July, depending on ongoing policy reviews.
Importers, meanwhile, say they are closely watching developments and remain concerned about renewed trade pressures even as they prepare refund claims.
“We’re really worried about that,” said Eugene Laney, president of the American Association of Exporters and Importers. “But even if they moved forward, I don’t believe it would reach the level of the previous tariffs.”
As the CAPE system goes live, attention now turns to whether the promised refunds will be processed efficiently—or become entangled in the same legal and bureaucratic complexities that shaped the tariffs themselves.
