
After the “Mess”: IEEPA Refunds and the Contractual Lessons for Businesses
As IEEPA refunds make their way back to importers, businesses are confronting a question that many commercial agreements never anticipated. Contracts frequently address who bears the cost when a new tariff is imposed, whether through a tariff surcharge, price-adjustment provision, or other pass-through mechanism. Far fewer address the opposite scenario: what happens when the tariff is later invalidated and the Importer of Record (“IOR”) receives the money back?








