IEEPA TARIFF REFUND RECOVERY FOR HOSPITALITY
You paid the tariff, even if you're not the importer.Here is how hotels and resorts recover that money.
Your FF&E and OS&E suppliers were 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 Opportunity
The downstream buyer opportunity in hospitality procurement
Hotels and resorts refresh guestroom furniture, fixtures & equipment (FF&E), operating supplies & equipment (OS&E), and technology on renovation and property improvement plan (PIP) cycles, largely through suppliers who import those goods directly. If tariff costs were built into your last renovation or replenishment order, the refund on that duty is flowing to your supplier, not to your property.
The Background
The refund is flowing back to your supplier — not to your property.
Between February 2025 and February 2026, importers paid more than $166 billion in IEEPA tariffs, a program that touched everything from guestroom furnishings to kitchen and operating equipment. On February 20, 2026, the U.S. Supreme Court ruled those tariffs unlawful, and CBP is now refunding the money. But the refund goes only to the Importer of Record (IOR) who filed the entry, typically your suppliers.
IEEPA tariffs collected nationwide, Feb 2025 to Feb 2026, across every sector including hospitality supply chains
Range of IEEPA tariff rates across 60+ countries over the life of the program, from the universal baseline to peak country-specific rates, applied to imported guestroom furnishings and operating equipment
Expected recovery on purchased imported guestroom FF&E, OS&E, and technology (renovation goods, amenities, and engineering equipment)
Why you cannot file with CBP directly
The CAPE refund portal accepts claims only from the Importer of Record named on the entry summary. Downstream buyers, including hotel owners, resorts, and management companies that purchased FF&E or OS&E through an importing supplier, have no direct administrative pathway with U.S. Customs.
Spend categories
Where this shows up in hospitality
Guestroom FF&E
Furniture, fixtures, and equipment for guest rooms.
Guest Supplies & Amenities
Toiletries, linens, and in-room amenities.
Operating Supplies & Equipment (OS&E)
Day-to-day operating goods across the property.
MRO & Engineering
Maintenance and engineering parts and supplies.
Technology & AV
In-room and property technology, AV, and entertainment systems.
How recovery works
Our five step process
The path runs through commercial channels, not CBP. The financial analysis is built by Sagemont using purchasing reports, invoices, purchase orders, supply agreements, tariff-related communications, and pricing notices. We map the pass-through, quantify your share, and work with your supplier for the portion of the refund attributable to costs you actually paid.
- 1
Intake & Estimates
Sagemont will analyze a single vendor transaction report, accompanied by all pricing communications from vendors, and provide you with estimates on the tariff recovery per supplier. This is a very light lift for clients.
- 2
Full Tariff Analysis
We pull invoices, purchase orders and vendor contracts to build on the initial analysis and map the exact tariff pass-through per supplier.
- 3
Supplier Communication
We work amicably with your suppliers on your behalf to present the analysis and follow up.
- 4
Methodology Review
Our team will review and validate the supplier's refund calculation and allocation against our analysis.
- 5
Tariff Refund Recovery
Recovered funds flow to you.
Contingency fees
No Recovery. No Fee.
We operate on a 100% contingency fee structure. There are zero upfront costs — if there is no recovery, you owe absolutely nothing.
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