Pagán is unsparing on the underlying principle: the administration was never entitled to the money in the first place. But there is a yawning chasm between having a legal right to a refund and actually obtaining one.
For fashion companies, the imperative is to move now, before the procedures are formalised. Santos is advising clients to file protests immediately to preserve their refund rights, preserve all documentation related to IEEPA tariff payments — import data, entry summaries, payment records, invoices and any CBP correspondence — and track inventory liquidation dates carefully. “We are helping many companies evaluate their import data and position themselves to quickly apply for refunds once the process has been developed,” she says.
The operational pressure is significant. Chris Desmond, a partner in PwC’s customs and international trade practice, warns that the refund process will arrive on top of an already stretched customs infrastructure. “Customs brokers will be under significant strain, with limited capacity to manage a surge of post-summary corrections and protests across thousands of importers,” he says. “Those that move quickly, with clear data and a defined strategy, will be far better positioned to get in front of the line as refund mechanisms take shape.”
Desmond advises companies to focus on three critical priorities: robust modelling of true opportunity and eligibility at the entry level; CFO-level attention to refund timing relative to seasonal cash needs; and honest accounting of execution risk.
There is also a downstream contractual question. Companies that restructured supplier relationships, renegotiated contracts or adjusted pricing explicitly in response to IEEPA tariffs may now face disputes over those arrangements, notes Santos. A review of material change provisions and any clawback mechanisms tied to tariff changes should happen immediately, she says.
Ali Furman, PwC’s consumer markets industry leader, frames the refund question in terms that will resonate with finance teams: any refunds received would likely be treated as one-time gains until cash is in hand, not as structural margin normalisation. “The strategic decision then becomes capital allocation,” she says — whether to reinvest in brand and retail experience, strengthen inventory positions ahead of key seasons, or improve price positioning in competitive categories. For luxury houses in particular, she cautions, any adjustment to pricing structure must be weighed against long-term brand equity signals.
If brands raised prices citing IEEPA tariffs, the question of whether they reverse those increases now is less straightforward than it might appear — and the answer, from some analysts, is: not yet, and possibly not at all.
Neil Saunders, managing director of GlobalData’s retail division, is blunt about consumer expectations: most shoppers have already absorbed elevated prices as the new normal. “The consumer is inflation-weary, so any reduction in prices would be welcomed,” he says. “However, most have already accepted that prices will remain elevated.” In theory, markets could penalise brands that maintain inflated pricing post-ruling — but in practice, he notes, disentangling tariff-driven increases from broader inflationary adjustments is a task few consumers will undertake.
Furman raises a point that cuts closer to brand reputation than to margin: companies that raised prices indiscriminately during the tariff period may face pressure to demonstrate that refunded duties benefit customers who bore those costs. “Retailers could use refunds to offset prior price increases through targeted promotions and/or provide one-time employee bonuses,” she says. How brands handled that calculus — whether they absorbed costs to protect customers or passed them through indiscriminately — may prove as consequential for long-term loyalty as the tariff exposure itself.
Diversification without reversal
One of the more consequential shifts of the IEEPA tariff era was in sourcing. According to Dr Sheng Lu, director of the department of fashion and apparel studies at the University of Delaware, China’s share of US apparel imports dropped from 20.9% in 2024 to 13.7% in 2025 — a structural change driven directly by tariff pressure. US fashion companies moved aggressively toward emerging suppliers in Cambodia, Pakistan, Jordan and Sri Lanka, while overall US apparel import growth lagged peer markets significantly: just 1.7% in the first 10 months of 2025, against 6 to 11% growth in the EU, UK and Japan.