$166B tariff refund portal - how Amazon sellers can claim

Any party listed as importer of record on a CBP Form 7501 entry summary that included an IEEPA surcharge between the implementation date and the March 2026 SCOTUS ruling. For Amazon sellers, this typically means whoever signed the customs entries: the brand owner, a third-party logistics provider acting under power of attorney, or in some cases the customs broker on behalf of the seller. Check your broker invoices and ACE portal entries to confirm who is listed.

The standard filing window is 180 days, but it is rolling and varies by HTSUS chapter. The 180-day clock starts on different dates for different product categories. Sellers importing textiles, electronics or home goods from China typically face the earliest deadlines, with many landing inside Q3 2026. Treat this as time-sensitive and prioritize by category exposure.

The cleanest accounting treatment is to book the refund as a COGS recovery in the original historical period, not as current-period income. This restates 2024 and 2025 margin to reflect the true cost basis. Booking it as current-period income inflates this year's margin and distorts trend analysis. Coordinate with your auditor before posting, especially if you have financing covenants or earn-out structures tied to historical EBITDA.

There is no legal requirement to pass refunds back to customers. Marketplace.org coverage shows businesses splitting roughly between retention, partial pass-through and full pass-through. The decision is operational and reputational rather than legal. Brands with visible category leadership face more scrutiny if competitors publicly cut prices. Most Amazon sellers are choosing partial pass-through for high-AOV SKUs and full retention on commodity items.