The Glossy Podcast A fashion brand’s guide to tariff refunds, with ArentFox Schiff’s Angela Santos
Mar 20, 2026
Angela Santos, partner and customs practice leader at ArentFox Schiff who advises on import compliance, tariffs and forced labor issues. She discusses the chaotic year for trade, the Supreme Court ruling fallout, the administration’s shift to Section 122 tariffs and how refunds might be issued. Practical next steps for brands and mitigation strategies like tariff engineering and supply-chain shifts are also covered.
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Supreme Court Win Didn’t Solve Refunds
- The Supreme Court struck down IEPA tariffs but did not address refunds, creating legal uncertainty.
- The administration immediately issued Section 122 tariffs to replicate IEPA effects, keeping instability for importers.
Judge Eaton Centralized Refund Decisions
- Judge Eaton consolidated refund determinations and ordered refunds for non-finalized entries pending an orderly process.
- He urged the government to avoid 300,000 individual suits and instead create a central ACE-based remedy.
Create An ACH Refund Account Now
- File an ACH refund account in ACE because CBP requires it for any electronic refund disbursement.
- The planned process asks importers to upload entry lists in ACE so Treasury can validate and issue electronic refunds.