US Tariffs After IEEPA: Collections, Refunds, Trade Data

Economic Warfare & Trade Policy Trade & tariffs

Photo: Container terminals at the Port of Long Beach, California. Don Ramey Logan via Wikimedia Commons (CC BY-SA 4.0).

U.S. tariffs after the IEEPA ruling look different in law but similar in scale. When the Supreme Court struck down the emergency tariffs on Feb. 20, 2026, the administration moved its duties onto three older trade statutes within five months. This investigation follows that rebuild through official records: what each legal authority does, who pays, what Treasury collected and refunded, and what Census trade data show so far.

Labels used in this report: Verified fact Official claim Expert interpretation Estimate Forecast

Executive summary

The tariff wall did not come down after the court ruling; it changed its legal basis, from emergency powers to statutes that require an investigation first.
Treasury’s own ledger shows the cost of the switch: refunds of struck-down duties swamped collections for three months in mid-2026, and net customs revenue for the fiscal year ended Sept. 30 came in below the year before.
Imports from China kept shrinking while imports from Mexico and Taiwan grew. The data show a shift in where goods come from, not proof that tariffs alone caused it.
Major legal questions remain open: refunds for importers who never sued, an appeal over the temporary global surcharge, and a court challenge to the new forced-labor tariffs.

Timeline

February 2025: The president begins using the International Emergency Economic Powers Act (IEEPA) to impose duties, later covering goods from nearly every country. Verified fact
Feb. 20, 2026: The Supreme Court holds in Learning Resources, Inc. v. Trump that IEEPA does not authorize those tariffs. The same day, Proclamation 11012 orders a 10% worldwide surcharge under Section 122 of the Trade Act of 1974. Verified fact
Feb. 24 to July 24, 2026: The Section 122 surcharge applies, the 150-day maximum the statute allows without Congress.
March 12, 2026: The U.S. Trade Representative opens 60 Section 301 investigations into whether trading partners ban imports made with forced labor.
May 7, 2026: The Court of International Trade rules the Section 122 surcharge unlawful in Oregon v. United States but limits relief to three importers; the appeals court stays that judgment.
July 24, 2026: Section 301 duties start on goods from the 60 economies.
Oct. 8, 2026: The trade court certifies a nationwide class of importers that paid IEEPA duties and have not sued.

The policy, explained

Each replacement authority works differently. Section 122 lets a president add up to 15% for no more than 150 days to address “fundamental international payments problems”; Proclamation 11012 cited the trade and current-account deficits, according to a legal analysis by Troutman Pepper Locke. Section 301 requires USTR to find a foreign practice unreasonable and burdensome to U.S. commerce. Section 232 requires a Commerce Department national-security investigation, product by product. The Congressional Research Service notes that, unlike IEEPA, both 301 and 232 need a completed investigation before duties apply.

The forced-labor action set four tiers, according to the Federal Register notice: a flat 10% for 17 economies that ban forced-labor imports or committed to do so, including Canada, Mexico, India and the United Kingdom; 10% or 12.5% “net of” the normal most-favored-nation rate for the European Union, Taiwan, Japan, South Korea and Switzerland, which caps the combined duty; and 12.5% for every other investigated economy. Verified fact USMCA-compliant goods and several categories of raw materials are exempt.

Affected countries

Every major partner is covered by at least one authority. China faces the 12.5% tier plus earlier Section 301 duties and the product-level Section 232 tariffs. Brazil has a separate 25% Section 301 tariff. Canada faces Section 338 duties of 50% on selected goods, with no USMCA exemption, and import bans on some products; our report on Canada-U.S. tariffs in fall 2026 covers that dispute. The full list of active actions, with rates and Federal Register citations, is on our Economic Warfare data dashboard.

Economic mechanisms

A tariff is paid by the U.S. importer of record when goods clear customs. Who ultimately bears it depends on how much of the cost the foreign seller absorbs, how much the importer passes on, and whether buyers switch suppliers. “Net of MFN” tiers matter because they cap the total duty rather than stacking on top. USMCA certification works as an off-switch for most Canadian and Mexican goods; the Budget Lab at Yale adjusts its tariff estimates for what it describes as rapid uptake of USMCA exemptions under the new regime.

Relevant statistics

U.S. customs duties, Treasury Monthly Treasury Statement (billions of dollars)
Period	Gross collected	Refunded	Net
Fiscal 2025 (Oct. 2024 to Sept. 2025)	202.4	7.5	194.9
Fiscal 2026 (Oct. 2025 to Sept. 2026)	317.8	144.6	173.2
June 2026 alone	23.6	49.2	-25.6

Verified fact Source: Treasury Fiscal Data, MTS Table 4. Net receipts were negative in June and July 2026 because refunds exceeded new collections.

U.S. goods imports by partner, January to August (billions of dollars, Census)
Partner	2025	2026	Change
China	219.3	183.5	-16.3%
Mexico	354.5	419.3	+18.3%
European Union	438.0	368.3	-15.9%
Taiwan	119.2	186.9	+56.8%
Canada	258.8	269.6	+4.2%

Verified fact Source: U.S. Census Bureau, trade in goods by country (nominal, not seasonally adjusted). On a full-year basis, imports from China fell from $440.3 billion in 2024 to $308.7 billion in 2025.

Stakeholder impacts

Importers paid duties that were later ruled unlawful and now depend on a refund process. U.S. Customs and Border Protection says refunds through its CAPE program are generally issued after it accepts an importer’s declaration. Official claim Importers that never sued may be covered by the certified class, but Troutman’s analysis says certification “is not a refund order.” Expert interpretation Households: the Yale Budget Lab estimates current-law tariffs cost about $1,100 per household a year and raise consumer prices by about 0.7%. Estimate The federal budget: refunds added to the fiscal 2026 deficit, which the Congressional Budget Office put near $2 trillion, as we reported in our October economic policy explainer.

Geopolitical objectives

USTR’s stated objective for the forced-labor action is to get partners to “impose and effectively enforce” bans on goods made with forced labor; the lower 10% tier rewards economies that have done so or committed to it in reciprocal trade agreements. Official claim Tariff-rate quotas for Bangladesh, Cambodia, Indonesia and Malaysia are tied to their purchases of U.S. cotton and textile inputs, which the notice describes as a way to reduce reliance on inputs more likely to involve forced labor. The Section 122 proclamation, by contrast, framed the surcharge as a response to the U.S. trade deficit.

Policy effectiveness

Keeping tariff levels in place: largely achieved on paper. The Budget Lab puts the average statutory rate at 11.0% on Aug. 24, 2026, after the Section 122 expiry, compared with under 3% at the start of 2025. Estimate Revenue: not achieved for fiscal 2026, because refunds of IEEPA duties outweighed the gains; the Treasury figures above show net receipts falling year over year. Partner forced-labor bans: too early to judge. The notice lists commitments, but we found no public count of new bans enacted since July. Trade balance with China: the bilateral goods deficit narrowed from $297.0 billion in 2024 to $202.7 billion in 2025, per Census. That is a correlation, not proof of cause: imports from Mexico and Taiwan rose over the same period, and demand, prices and exchange rates also moved, so the data cannot isolate the tariff effect.

Unintended consequences

Legal instability is itself a cost. Importers have paid duties under four different legal authorities since early 2025, and the Budget Lab counts more than forty revisions to U.S. tariff rates since early 2025. Refund litigation created a two-tier system: importers with their own suits are excluded from the class, while a two-year filing deadline applies to individual claims, according to Troutman. The swing in Treasury’s monthly receipts complicated budget projections at the same time Congress was negotiating funding.

Future scenarios

Status quo: Section 301 and 232 duties stay, and the statutory average rises to about 11.8% by year-end as scheduled increases take effect. Forecast (Yale Budget Lab)
Court setback: the trade court sets aside the forced-labor determinations, opening a second refund wave. No decision had been issued as of mid-October.
Negotiated exits: more partners commit to forced-labor bans and move to the 10% tier, or secure product exemptions through trade agreements.
Escalation: pending Section 301 probes into excess manufacturing capacity and Section 232 cases on robotics, wind turbines and medical equipment add new duties.

Additional details

Section 122’s 150-day limit can only be extended by Congress. The forced-labor notice drew more than 2,100 public comments during the investigation phase and over 1,600 on the proposed action, according to USTR. The Budget Lab estimates current-law tariffs would raise about $1.9 trillion over ten years before accounting for slower growth. Estimate For the running list of trade actions, see the Trump presidency tracker.

Sources

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US Tariffs After the IEEPA Ruling: How the Duties Were Rebuilt