CBP Issues Notice on Tariff “Stacking” Refunds: What Importers Need to Know

ByAnnik Sobing

On May 16, 2025, U.S. Customs and Border Protection (CBP) released a significant notice that addresses the issue of tariff “stacking”-the practice of applying multiple, overlapping tariffs to the same imported goods. This move comes as part of the implementation of President Donald Trump’s Executive Order (EO) 14289, which aims to eliminate the accumulation of certain tariffs and provide relief to importers affected by these overlapping charges.

What Is Tariff Stacking?

Tariff stacking occurs when more than one tariff is applied to the same product, often due to overlapping trade enforcement programs. In this case, the affected tariffs include:

  • IEEPA tariffs on goods from Canada and Mexico
  • Section 232 tariffs on automobiles and automotive parts
  • Section 232 tariffs on steel and aluminum

These overlapping tariffs have led to higher costs for importers and, ultimately, for consumers.

Key Points from the CBP Notice

The CBP notice provides clear guidance for importers seeking refunds for tariffs that were previously “stacked” in violation of the new executive order:

  • Refund Eligibility: Importers can now request refunds for tariffs that were improperly stacked.
  • Effective Date: The refund process applies to entries from May 16, 2025, onward.
  • How to File:
    • For unliquidated entries (entries not yet finalized by CBP), importers should file a Post Summary Correction (PSC).
    • For liquidated entries (entries already finalized, but within the protest period), importers should file a protest under 19 U.S.C. 1514.

Why This Matters

This update is a major development for businesses importing goods subject to these tariffs. The ability to reclaim overpaid duties could result in significant cost savings and improved cash flow for affected companies. Importers should review their recent entries to determine if they are eligible for refunds and take prompt action to file the appropriate corrections or protests.

Next Steps for Importers

  1. Review Import Records: Identify entries where overlapping tariffs may have been applied.
  2. Determine Entry Status: Check if the entries are unliquidated or liquidated (but still within the protest period).
  3. File the Correct Form: Submit a PSC for unliquidated entries or a protest for eligible liquidated entries.
  4. Consult with Trade Counsel: Given the complexity of tariff regulations, consider seeking legal or customs broker assistance to ensure compliance and maximize potential refunds.
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Resource:
For more details, see the original notice and analysis at Thompson Hine: CBP Issues Notice Addressing Refunds to Address Tariff “Stacking” Updates

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