Amazon sellers who import products directly into the United States may be eligible for IEEPA tariff refunds — but eligibility depends entirely on who is listed as the importer of record on the customs entries. The February 2026 Supreme Court ruling in Learning Resources v. Trump struck down $166 billion in IEEPA tariffs in a 6-3 decision, and the refund belongs exclusively to the entity named on CBP Form 7501.
Our eligibility checker evaluates this as the first of four screening criteria. For Amazon sellers specifically, the importer of record question is where most confusion arises.
FBA sellers who import directly
If you source products from China, Vietnam, India, or other IEEPA-affected countries and import them into the U.S. under your own name (or your company’s name), you are the importer of record. The refund belongs to you.
This is true even if:
- Your customs broker files the entries on your behalf
- The goods go directly to an Amazon fulfillment center
- You use a freight forwarder to arrange ocean or air shipping
- You never physically handle the inventory
What matters is whose name appears on CBP Form 7501 and whose IOR number is associated with the customs entry in CBP’s ACE system. Your customs broker can confirm this in seconds. For a detailed walkthrough of confirming your IOR status, see finding your importer of record status.
When Amazon is the IOR
In some cases, Amazon itself imports goods and is listed as the importer of record. This happens with certain first-party vendor arrangements where Amazon purchases inventory outright and handles importation. If Amazon is the IOR on those entries, the refund belongs to Amazon, not to you.
This distinction applies regardless of whether you sell through Vendor Central or Seller Central. The determining factor is not your Amazon relationship — it is whose name appears on the customs entry.
Sellers using third-party importers
Some Amazon sellers use third-party import services where the service company is listed as the IOR. In these arrangements, the refund belongs to the entity on the customs entry — not the seller. If this applies to you, contact your import service to discuss the refund and whether any contractual provisions address tariff recoveries.
How to check your status
The eligibility checker walks you through confirming your IOR status as the first of four criteria. The four-criteria screening evaluates: importer of record status, affected country of origin, HTS code classification under 9903.01 or 9903.02, and minimum import volume.
If you are unsure about your IOR status, the simplest approach is to ask your customs broker or check any CF-7501 entry summary from the covered period (February 2025 through February 2026). You can also verify through the ACE Secure Data Portal if you have direct access. For detailed instructions on pulling your data, see how to export your ES-003 report.
Volume considerations for Amazon sellers
Amazon sellers span a wide range of import volumes. There is no minimum threshold for IEEPA refund eligibility. Whether you imported $10,000 or $10 million in affected goods, you may qualify. The Supreme Court ruling in Learning Resources v. Trump applies equally regardless of volume — the constitutional deficiency does not depend on the amount collected.
However, the optimal recovery path varies by exposure level:
Under $50,000 exposure: Self-directed recovery through CBP’s upcoming CAPE portal is likely the most practical approach. The economics of a formal assessment may not justify the time investment for smaller sellers.
$50,000 to $500,000: A guided Impact Assessment adds significant value by identifying which entries are approaching protest deadlines and mapping the most efficient recovery route. Many mid-volume Amazon sellers fall into this range.
Over $500,000: Full assessment with detailed entry-level analysis at tariffresolution.com. Multiple recovery paths likely apply to different subsets of your entries. For importers who prefer immediate capital over government processing timelines, tariffbuyouts.com facilitates non-recourse claim acquisition.
China-sourced inventory: IEEPA vs. Section 301
Amazon sellers who source from China face an additional complexity. Your entries may include both IEEPA tariffs (refundable, HTS 9903.01 and 9903.02) and Section 301 tariffs (not refundable, HTS 9903.88). The Section 301 tariffs have been in effect since 2018 and were not affected by the Supreme Court ruling.
A full assessment separates these precisely, calculating only the IEEPA portion. For China-specific guidance on rates, HTS codes, and refund calculations, see chinatariffrefund.com. For a detailed comparison of which tariffs are and are not refundable, see Section 301 vs. IEEPA.
Marketplace sellers beyond Amazon
The same rules apply to sellers on Walmart Marketplace, Shopify, Target Plus, and other platforms. The platform you sell on does not affect your IEEPA refund eligibility. What matters is whether you are the importer of record on the underlying customs entries.
If you import directly and your company name appears on the CF-7501, you qualify for the same refund as any traditional importer. The eligibility checker confirms this in under two minutes regardless of which marketplace you sell on.
Next steps
Screen your eligibility to confirm your qualification status. If you pass all four criteria and your annual import volume exceeds $50,000, request a full Impact Assessment to see your specific recoverable amount and recommended recovery path. Customs brokers and trade attorneys in the partner network can coordinate directly with your broker of record if you need assistance pulling entry data.