IEEPA Recovery
You Absorbed the Tariff.
Here's How to Get It Back.
If your supplier was the Importer of Record, CBP's refund goes to them. We recover your share.
No retainers. No hourly billing. You pay nothing unless we recover.
The Situation
Your Supplier Is Getting Paid Back. You're Not.
From early 2025 through February 2026, U.S. businesses paid over $166 billion in IEEPA tariffs. When the Supreme Court struck those tariffs down on February 20, 2026, U.S. Customs and Border Protection (CBP) began processing refunds — but the money only flows back to the Importer of Record (IOR), the party named on the original customs entry.
For most downstream buyers, that's not you. If your supplier imported the goods and recovered their tariff costs through your invoices, you funded that duty. CBP doesn't know that. Their refund goes to the IOR, and there is no automatic mechanism to get your share back.
That does not mean the money is gone.
There is a legal pathway to recover your share — it just does not run through CBP. Sagemont builds the case against your supplier, pursues your claim through commercial and legal channels, and returns what you are owed. That is what we do.
Why Sagemont
Built for recovery work
Credits and incentives recovered for clients
Businesses served across industries
In-house CPAs and attorneys working every claim — not outsourced
Sagemont has spent years finding money that belongs to our clients and bringing it back. IEEPA downstream recovery is the newest application of that same work — we know how suppliers structure pass-throughs, how supply agreements are written, and where the leverage is.
We handle everything from intake through resolution. Most clients spend less than a few hours on the entire engagement. We do the rest, on contingency.
How It Works
How Recovery Works
CBP's refund process runs entirely through the CAPE (Consolidated Administration and Processing of Entries) portal — and it only accepts claims from the IOR. If your name is not on the entry, there is no form to file and no exception process. CBP cannot help you.
That does not mean the money is gone.
There may be a path to recover your share of these costs, though it does not involve seeking a refund directly from CBP. Sagemont works with clients to evaluate potential recovery opportunities, engage with suppliers, and pursue available commercial or legal avenues where appropriate. Our goal is to help clients recover amounts they may be entitled to and return those funds to the businesses that incurred the costs.
Unjust Enrichment
If your supplier collects a refund for costs you paid, keeping that money may constitute unjust enrichment under applicable state law.
Breach of Contract
Many supply agreements include price protection clauses, most-favored-nation provisions, or duty pass-through language that supports a contractual claim.
Implied Covenant of Good Faith & Fair Dealing
Available under UCC Article 2 in most commercial goods transactions.
Process
Our Process
Assess
We review your purchase history, map which suppliers acted as the Importer of Record (IOR), and identify which transactions are eligible for recovery. You get a recovery estimate before we go any further.
Build
We assemble the full evidentiary record — invoices, contracts, pricing notices, and supplier communications — to establish the economic pass-through and quantify your share of the duty paid.
Pursue
We issue formal written notice to your supplier, confirm their IOR status and CAPE filing activity, and present a pro-rata allocation methodology based on documented costs you absorbed.
Negotiate
We engage directly with the supplier on the refund calculation and allocation. Where their numbers don't hold up, we push back with the documentation. The majority of claims reach resolution at this stage.
Escalate
When a supplier refuses to remit or proposes terms that don't reflect the actual pass-through, our attorneys engage on breach of contract, unjust enrichment, and implied covenant grounds.
Recover
Funds are remitted to you. Our fee is contingency-based and comes only from what we recover on your behalf.
No Recovery. No Fee.
Sagemont works entirely on contingency. No retainers, no hourly billing, no upfront costs. If we don't recover money for you, you owe us nothing.
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