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FAQ

Tariff Refund FAQ

Frequently asked questions about IEEPA tariff refunds, CAPE declarations, Section 301 recovery, customs broker partnerships, and consumer refunds.

General

Common questions about tariff refunds and the CAPE program

  • How do I get a tariff refund?

    Upload your ACE ES-003 entry-summary CSV to Tariffi. Our platform analyzes your entries for IEEPA and Section 301 overpayments, prepares the CAPE declaration data, and routes it to a CBP-licensed customs broker partner who files under their own license. No advance fees — you pay a contingency only when CBP approves your refund.

    Read full answer →
  • What is the CAPE program?

    CAPE (Customs Automated Protest and Entry) is CBP's electronic program for processing tariff refund declarations. Importers who overpaid IEEPA or Section 301 tariffs submit CAPE declarations through the ACE portal. Tariffi automates the data preparation; your licensed customs broker partner transmits the declaration under their ABI filer code.

    Read full answer →
  • Am I eligible for an IEEPA tariff refund?

    You may be eligible if you are a U.S. importer of record who paid tariffs under the International Emergency Economic Powers Act on qualifying entries within the CAPE lookback window. Upload your ES-003 entry-summary CSV and Tariffi analyzes each entry's eligibility automatically — no commitment required to check.

    Read full answer →
  • How long does a tariff refund take?

    Refund timing is governed by federal statute, not by Tariffi. CBP has up to two years to decide a protest under 19 U.S.C. § 1515, though most CAPE Phase 1 claims process faster. After CBP allows your claim, Treasury ACHs the refund within 3-5 business days. CIT filings for older entries add court calendar time.

    Read full answer →
  • What documents do I need to file a CAPE declaration?

    You need your ES-003 entry-summary CSV from the ACE portal — the universal export every U.S. broker and importer of record can produce. Tariffi extracts all required data (entry numbers, HTS codes, duty amounts, liquidation dates) from this single file. No additional paperwork is required to start the process.

    Read full answer →
  • How much can I recover from Section 301 tariffs?

    Recovery amounts depend on how much Section 301 duty you overpaid on qualifying entries. The CAPE Phase 1 pool exceeds $20 billion across all eligible importers. Upload your ES-003 and Tariffi calculates your specific estimated recovery per entry based on the tariff differential and your actual duty payments.

    Read full answer →
  • What is an ES-003 file and how do I get it?

    An ES-003 is CBP's standardized entry-summary export from the ACE portal in CSV format. It contains all data needed for CAPE declarations: entry numbers, HTS codes, duty amounts, and liquidation dates. Your customs broker can pull it, or you can export it directly from ace.cbp.gov if you have portal access.

    Read full answer →
  • Do I need a customs broker for a tariff refund?

    Yes. Federal law (19 U.S.C. § 1641) requires a CBP-licensed customs broker to file CAPE declarations. Tariffi is a data-preparation platform, not a broker — we prepare your declaration data and route it to a licensed broker partner who reviews, approves, and transmits under their own ABI filer code at no extra cost to you.

    Read full answer →
  • What is the deadline for CAPE Phase 1?

    CAPE Phase 1 does not have a single batch deadline. Each entry has its own 180-day protest window per 19 CFR § 174.12 starting from the liquidation date. Entries that have already passed this window may still qualify through a protective CIT filing. File sooner to capture more entries before their individual windows close.

    Read full answer →
  • How much does Tariffi charge?

    Tariffi charges a contingency-only fee with three tiers: 10% on unliquidated entries, 15% on recently liquidated entries (within 180 days), and 25% on entries requiring CIT protective filing. No retainer, no advance fees, no deposits. If CBP denies your claim, you owe nothing on the denied portion.

    Read full answer →
  • Are there any upfront fees?

    No. Tariffi charges zero advance fees, zero retainers, and zero deposits. You pay only a contingency fee when CBP approves your refund and Treasury sends the money. This is not just a policy — it is a legal requirement under 16 CFR § 310.4(a)(2), the federal Telemarketing Sales Rule.

    Read full answer →
  • What happens if CBP denies my claim?

    If CBP denies any entry in your CAPE declaration, you owe nothing on the denied portion. Your broker partner (Filer of Record) responds to any CBP Form 28 or Form 29 within the scope of the LPOA at no additional charge. For entries worth contesting, the broker may file a further protest or recommend CIT action.

    Read full answer →
  • What is the difference between IEEPA and Section 301?

    IEEPA tariffs are imposed under the International Emergency Economic Powers Act during declared national emergencies. Section 301 tariffs are imposed under the Trade Act of 1974 to counter unfair trade practices, primarily targeting Chinese imports across four tranches. Both create refund opportunities through CAPE — Tariffi handles both.

    Read full answer →
  • Can I file a CAPE declaration myself?

    Technically yes, if you have ACE portal access and a licensed customs broker willing to file. However, preparing the declaration data requires cross-referencing entry-level HTS codes against the CAPE-eligible tariff schedule, calculating duty differentials, and formatting to CBP's specifications. Tariffi automates this and includes broker filing at no extra cost.

    Read full answer →
  • What products are affected by IEEPA and Section 301 tariffs?

    Section 301 tariffs primarily affect goods imported from China across four lists covering thousands of product categories: electronics, machinery, textiles, furniture, auto parts, toys, chemicals, and more. IEEPA tariffs can target goods from any country under an emergency declaration. Specific product coverage depends on the HTS codes in each tariff action.

    Read full answer →
  • How is Tariffi different from other tariff refund services?

    Tariffi is a data-preparation platform with a contingency-only fee (10/15/25%), no advance fees, and broker-compliant architecture per CBP Ruling HQ H326926. We never file with CBP directly — your licensed broker partner is always the Filer of Record. The ES-003-only intake keeps preparation deterministic and auditable under 19 CFR Part 163.

    Read full answer →
Importers

For U.S. importers of record seeking IEEPA and Section 301 refunds

  • How do I get a tariff refund?

    Upload your ACE ES-003 entry-summary CSV to Tariffi. Our platform analyzes your entries for IEEPA and Section 301 overpayments, prepares the CAPE declaration data, and routes it to a CBP-licensed customs broker partner who files under their own license. No advance fees — you pay a contingency only when CBP approves your refund.

    Read full answer →
  • What is the CAPE program?

    CAPE (Customs Automated Protest and Entry) is CBP's electronic program for processing tariff refund declarations. Importers who overpaid IEEPA or Section 301 tariffs submit CAPE declarations through the ACE portal. Tariffi automates the data preparation; your licensed customs broker partner transmits the declaration under their ABI filer code.

    Read full answer →
  • Am I eligible for an IEEPA tariff refund?

    You may be eligible if you are a U.S. importer of record who paid tariffs under the International Emergency Economic Powers Act on qualifying entries within the CAPE lookback window. Upload your ES-003 entry-summary CSV and Tariffi analyzes each entry's eligibility automatically — no commitment required to check.

    Read full answer →
  • How long does a tariff refund take?

    Refund timing is governed by federal statute, not by Tariffi. CBP has up to two years to decide a protest under 19 U.S.C. § 1515, though most CAPE Phase 1 claims process faster. After CBP allows your claim, Treasury ACHs the refund within 3-5 business days. CIT filings for older entries add court calendar time.

    Read full answer →
  • What documents do I need to file a CAPE declaration?

    You need your ES-003 entry-summary CSV from the ACE portal — the universal export every U.S. broker and importer of record can produce. Tariffi extracts all required data (entry numbers, HTS codes, duty amounts, liquidation dates) from this single file. No additional paperwork is required to start the process.

    Read full answer →
  • How much can I recover from Section 301 tariffs?

    Recovery amounts depend on how much Section 301 duty you overpaid on qualifying entries. The CAPE Phase 1 pool exceeds $20 billion across all eligible importers. Upload your ES-003 and Tariffi calculates your specific estimated recovery per entry based on the tariff differential and your actual duty payments.

    Read full answer →
  • What is an ES-003 file and how do I get it?

    An ES-003 is CBP's standardized entry-summary export from the ACE portal in CSV format. It contains all data needed for CAPE declarations: entry numbers, HTS codes, duty amounts, and liquidation dates. Your customs broker can pull it, or you can export it directly from ace.cbp.gov if you have portal access.

    Read full answer →
  • Do I need a customs broker for a tariff refund?

    Yes. Federal law (19 U.S.C. § 1641) requires a CBP-licensed customs broker to file CAPE declarations. Tariffi is a data-preparation platform, not a broker — we prepare your declaration data and route it to a licensed broker partner who reviews, approves, and transmits under their own ABI filer code at no extra cost to you.

    Read full answer →
  • What is the deadline for CAPE Phase 1?

    CAPE Phase 1 does not have a single batch deadline. Each entry has its own 180-day protest window per 19 CFR § 174.12 starting from the liquidation date. Entries that have already passed this window may still qualify through a protective CIT filing. File sooner to capture more entries before their individual windows close.

    Read full answer →
  • How much does Tariffi charge?

    Tariffi charges a contingency-only fee with three tiers: 10% on unliquidated entries, 15% on recently liquidated entries (within 180 days), and 25% on entries requiring CIT protective filing. No retainer, no advance fees, no deposits. If CBP denies your claim, you owe nothing on the denied portion.

    Read full answer →
  • Are there any upfront fees?

    No. Tariffi charges zero advance fees, zero retainers, and zero deposits. You pay only a contingency fee when CBP approves your refund and Treasury sends the money. This is not just a policy — it is a legal requirement under 16 CFR § 310.4(a)(2), the federal Telemarketing Sales Rule.

    Read full answer →
  • What happens if CBP denies my claim?

    If CBP denies any entry in your CAPE declaration, you owe nothing on the denied portion. Your broker partner (Filer of Record) responds to any CBP Form 28 or Form 29 within the scope of the LPOA at no additional charge. For entries worth contesting, the broker may file a further protest or recommend CIT action.

    Read full answer →
  • What is the difference between IEEPA and Section 301?

    IEEPA tariffs are imposed under the International Emergency Economic Powers Act during declared national emergencies. Section 301 tariffs are imposed under the Trade Act of 1974 to counter unfair trade practices, primarily targeting Chinese imports across four tranches. Both create refund opportunities through CAPE — Tariffi handles both.

    Read full answer →
  • Can I file a CAPE declaration myself?

    Technically yes, if you have ACE portal access and a licensed customs broker willing to file. However, preparing the declaration data requires cross-referencing entry-level HTS codes against the CAPE-eligible tariff schedule, calculating duty differentials, and formatting to CBP's specifications. Tariffi automates this and includes broker filing at no extra cost.

    Read full answer →
  • How do I know if my entries are eligible?

    Upload your ES-003 entry-summary CSV at tariffi.io/intake/start. Tariffi's analysis engine automatically cross-references each entry's HTS codes against the CAPE-eligible tariff schedule, checks liquidation status, identifies disqualifying factors, and shows you a per-entry breakdown of eligible amounts and applicable fee tiers.

    Read full answer →
  • How is Tariffi different from a law firm?

    Law firms typically bill $1,000-1,200/hour plus a 15-40% contingency and take 6-18 months. Tariffi charges a tiered 10-25% contingency only, targets 8-12 weeks from filing to Treasury settlement, and never bills hourly. We prep the data; a licensed customs broker files. For CIT litigation, hire a law firm. For CAPE refund recovery, use Tariffi.

    Read full answer →
  • Where does my refund money go after CBP approves?

    After CBP allows your claim, Treasury ACHs the refund to Tariffi's dedicated client-funds account at JPMorgan Chase Bank. The automated fee split deducts the contingency, and your net refund ACHs to the bank account you provided at intake. Total time from CBP allow-decision to your bank: typically 3-5 business days.

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  • What is the difference between a CBP protest and a CAPE declaration?

    A CBP protest under 19 U.S.C. § 1514 is the traditional mechanism for challenging individual customs decisions. A CAPE declaration is the streamlined electronic format specifically designed for tariff refund claims, covering multiple entries in a single filing. CAPE is faster and less documentation-intensive than traditional protests for qualifying entries.

    Read full answer →
  • What is the ACE portal?

    ACE (Automated Commercial Environment) is CBP's online portal for processing trade-related transactions. Importers and brokers use ACE to file entry summaries, manage protests, submit CAPE declarations, and configure ACH refund information. You do not need direct ACE access to use Tariffi — your customs broker partner handles ACE transmission.

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  • What does 'liquidation' mean for customs entries?

    Liquidation is CBP's final determination of the duties, taxes, and fees owed on a customs entry. Once an entry is liquidated, the 180-day protest window starts. Unliquidated entries get the lowest Tariffi fee tier (10%), recently liquidated entries are 15%, and entries liquidated beyond 180 days require CIT filing at 25%.

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  • What is a Limited Power of Attorney (LPOA)?

    An LPOA authorizes a licensed customs broker to act on your behalf for specific customs transactions — in this case, filing CAPE declarations. You sign the LPOA directly with the broker partner (not with Tariffi) during intake. It is limited in scope to CAPE filings and does not give the broker authority over your other customs business.

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  • What is an HTS code and why does it matter for refunds?

    An HTS (Harmonized Tariff Schedule) code is a 10-digit classification that identifies the tariff rate applied to an imported product. HTS codes determine whether your entries are subject to IEEPA or Section 301 tariffs and thus eligible for CAPE refunds. Tariffi cross-references your ES-003 HTS codes against the CAPE-eligible schedule automatically.

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  • Can I track my claim status?

    Yes. Your dashboard at tariffi.io/dashboard shows real-time claim status including entry-level progress, broker review status, CBP submission confirmation, and payout tracking. Every status milestone also triggers an email notification. If you have not received an update in 90 days, contact support — silence usually means we are waiting on CBP.

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  • Do you handle drawback claims?

    No. Tariffi focuses exclusively on CAPE declarations for IEEPA and Section 301 tariff refunds. Duty drawback (19 U.S.C. § 1313) is a separate CBP program for recovering duties on goods that are re-exported or destroyed. If your entries have existing drawback claims, Tariffi flags the conflict to avoid duplicate filing issues.

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  • What if I changed customs brokers during the tariff period?

    No problem. Tariffi supports multi-file upload from multiple brokers. Upload ES-003 exports from each broker who filed entries on your behalf. Our platform groups entries by IOR number across all files and routes CAPE declarations to the appropriate broker partner for each set of entries based on the original Filer Code.

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  • Is my data secure with Tariffi?

    Yes. Tariffi uses AES-256 encryption at rest, TLS 1.2+ in transit, role-scoped database access with audit logging, and 7-year data retention per 19 CFR Part 163. ES-003 files are archived to cold storage with year-segmented paths and lifecycle deletion policies. Pre-signed download URLs expire after 60 seconds.

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  • What are CBP Form 28 and Form 29?

    Form 28 (Request for Information) is CBP asking for additional documentation to evaluate your entry. Form 29 (Notice of Action) is CBP notifying you of a proposed change to your entry, including a potential denial. Your broker partner (Filer of Record) responds to both within the LPOA scope at no additional charge through Tariffi's engagement.

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  • What is a CIT protective filing?

    A CIT (Court of International Trade) protective filing is a legal action filed in federal court to preserve your refund rights on entries whose 180-day protest window has closed. It is the mechanism for older liquidated entries that can no longer use the standard CBP protest process. Tariffi facilitates CIT filings at the 25% contingency tier.

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  • Can I cancel after signing the engagement?

    Yes. You can revoke the LPOA and terminate the Contingency Fee Agreement by written notice at any time before the CAPE declaration is filed with CBP. Once filed, the broker is the Filer of Record and the engagement continues through the claim lifecycle. Contact support@tariffi.io to initiate cancellation.

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  • What does 'Filer of Record' mean?

    The Filer of Record is the CBP-licensed customs broker whose name, license number, and ABI filer code appear on a CAPE declaration or protest filed with CBP. The Filer of Record bears professional responsibility for the filing under 19 CFR Part 111. At Tariffi, the broker partner is always the Filer of Record — we prepare data but never file.

    Read full answer →
  • What happens after CBP approves my CAPE declaration?

    After CBP allows your declaration, Treasury ACHs the refund to Tariffi's dedicated client-funds account within 2 business days. The fee split happens automatically on arrival. Your net refund ACHs to your bank within 3-5 business days total from the allow-decision. You get email notifications at each step.

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Mid-Market

For importers with $500K-$5M in duty paid and multi-broker portfolios

  • What does underwriter-led discovery mean?

    A named Tariffi underwriter owns your portfolio kickoff: eligibility scan across all your Filer Codes, recovery-probability heatmap per entry vintage, and a single readout before any filing goes to broker review. Underwriter-led is for importers with multi-broker portfolios where standard self-serve intake would miss cross-broker edge cases.

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  • We use multiple customs brokers. Do you work with all of them?

    Yes. Tariffi's partnership architecture is broker-agnostic — we route each entry's preparation to the licensed broker who already has the ABI Filer Code for that entry. No broker-switch disruption. If a broker we have not partnered with yet owns some of your filings, we onboard them on your timeline.

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  • Do you support our internal compliance diligence?

    Yes. Tariffi provides a diligence pack on request that includes broker-partnership regulatory evidence (19 CFR Part 111, CBP Rulings HQ H326926 and H350722), a FASB ASC 450-30 contingent-recovery memo template, and the full engagement-letter redline — all under NDA.

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Enterprise

For importers with $5M+ in duty paid requiring custom engagement structures

  • What's different about enterprise pricing?

    Enterprise importers ($5M+ duty paid) receive custom-priced contingency below the standard 10/15/25% tiers, a co-advisory engagement structure that accommodates existing tax or trade counsel, and a dedicated underwriter. Volume-based fee negotiation starts at the first conversation. Contact enterprise@tariffi.io.

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  • How do you handle procurement diligence?

    Tariffi provides a complete diligence package under NDA: broker-partnership regulatory evidence (19 CFR Part 111, CBP Rulings HQ H326926 and H350722), FASB ASC 450-30 contingent-recovery memo template, engagement letter redline, security posture documentation (AES-256, TLS 1.2+, 7-year retention), and reference contacts from comparable engagements.

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  • Do you work with Big 4 advisors?

    Yes. Tariffi's enterprise engagement structure accommodates co-advisory arrangements where your existing Big 4 tax or trade team owns the workpaper review. A licensed customs broker partner transmits to CBP under their own license per 19 CFR Part 111. The engagement letter accommodates a side arrangement with your advisor.

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  • What about IRC section 482 related-party imports?

    Related-party imports under IRC section 482 have additional customs valuation considerations that affect CAPE eligibility. Tariffi's analysis engine flags related-party entries for special handling, and the licensed broker partner applies enhanced review. Enterprise engagements include coordination with your transfer-pricing advisors if needed.

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  • What is your security posture?

    AES-256 encryption at rest, TLS 1.2+ in transit, role-scoped database access with audit logging, 7-year data retention per 19 CFR Part 163, and broker tenant isolation at the database layer. Under NDA we share penetration-test summaries and subprocessor attestations. Additional certifications disclosed as they become available.

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Brokers

For CBP-licensed customs brokers considering a Tariffi partnership

  • How does the Tariffi broker partnership work?

    Tariffi prepares CAPE declaration data from importers' ES-003 files and routes it to your broker portal for review. You remain Filer of Record on every filing under your own ABI filer code. Tariffi never touches CBP servers. You earn a flat per-filing filer integration fee per 19 CFR § 111.36(c) — never a percentage.

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  • Will Tariffi file anything under my license?

    No. Tariffi is a data-preparation platform — we never access CBP servers or file anything under your license. You review every CAPE declaration in your broker portal, approve it with your professional judgment, and transmit it via your own ABI filer code through ACE. You are always the Filer of Record.

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  • How are brokers compensated?

    Brokers receive a flat per-filing filer integration fee per 19 CFR § 111.36(c). The fee is paid by Tariffi on the importer's behalf and invoiced promptly after filing confirmation. It is never a percentage of the importer's refund, never a referral bounty, and never volume-based — structures that would violate § 111.36(b).

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  • Is my customs broker license at risk?

    No. Tariffi's architecture is designed specifically to protect your license. You remain Filer of Record, apply all professional judgment, and transmit via your own ABI filer code. Compensation is a flat per-filing fee per 19 CFR § 111.36(c) — no percentage splits that would trigger § 111.36(b) scrutiny. Our structure follows CBP Ruling HQ H326926.

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  • What about client confidentiality?

    Each broker partner has an isolated tenant — you see only CAPE filings assigned to your Filer Code. Tenant isolation is enforced at the database layer with role-scoped access and audit logging. No cross-broker visibility, no aggregated client lists, and the partnership agreement bars Tariffi from soliciting your clients for customs brokerage services.

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  • What does 'Filer of Record' mean?

    The Filer of Record is the CBP-licensed customs broker whose name, license number, and ABI filer code appear on a CAPE declaration or protest filed with CBP. The Filer of Record bears professional responsibility for the filing under 19 CFR Part 111. At Tariffi, the broker partner is always the Filer of Record — we prepare data but never file.

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Consumers

For end consumers affected by tariff passthrough pricing

  • Can consumers get tariff refunds?

    Yes, through Tariffi's B2B2C consumer refund distribution program. When importers and retailers recover tariff overpayments, a portion of those savings can flow through to end consumers who purchased affected products. Check your eligibility at tariffi.io to see if any of your recent purchases qualify for a refund.

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  • How much did tariffs cost me as a consumer?

    IEEPA and Section 301 tariffs added 7.5% to 25% to the cost of affected imported goods, primarily from China. On a $100 purchase, that means $7.50 to $25 in embedded tariff costs passed through as higher retail prices. Your actual exposure depends on what you bought, when, and from which retailers.

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  • How do I check if I'm owed a tariff refund?

    Visit tariffi.io and follow the consumer eligibility check flow. You will need basic information about your purchases: retailer name, approximate purchase dates, and product categories. Tariffi cross-references your purchases against participating retailers and tariff-affected product categories to determine if you qualify for a consumer refund.

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  • What is tariff passthrough?

    Tariff passthrough is when importers pass the cost of tariffs through to downstream buyers via higher wholesale and retail prices. Studies show that Section 301 and IEEPA tariffs are largely passed through to U.S. consumers, meaning the economic burden falls on end purchasers, not the foreign exporters the tariffs target.

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  • How is this different from a class action?

    Tariffi's consumer refund distribution is a voluntary program, not litigation. Participating retailers and importers opt in to distribute refunds. There are no legal fees, no court proceedings, no settlement timelines, and no attorney contingency. You receive your refund directly through the platform — typically within days of claiming, not years.

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  • Is there a fee for consumer tariff refunds?

    A small liquidity retention fee of 7.5% is applied to consumer refund distributions. This covers the costs of matching purchases to tariff-affected products, processing refund payments, and maintaining the consumer distribution platform. There are no upfront fees, and the fee is deducted automatically from your refund amount.

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  • What products are affected by IEEPA and Section 301 tariffs?

    Section 301 tariffs primarily affect goods imported from China across four lists covering thousands of product categories: electronics, machinery, textiles, furniture, auto parts, toys, chemicals, and more. IEEPA tariffs can target goods from any country under an emergency declaration. Specific product coverage depends on the HTS codes in each tariff action.

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  • How are consumer refunds paid out?

    Consumer refunds are paid via ACH direct deposit, digital wallet (Venmo, PayPal, etc.), or prepaid virtual card — depending on your preference and the participating retailer's distribution channel. Refunds typically arrive within a few business days of claiming. There are no paper checks and no waiting for a court settlement.

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Questions? support@tariffi.io