Post–Election Insight: What Do Election Outcomes Mean for the Country, Your Industry, and Your Company?

Overview On March 11, 2026, independent reports confirmed that one of the largest medical device companies in the United States was the…

The conundrum for companies that indirectly paid the IEEPA tariffs, such as those that re-ceived price increases or outright tariff surcharges, is that the importing system is set up so that all refunds will be made by CBP directly to the importer of record. Nonetheless, compa-nies that indirectly paid the IEEPA tariffs may have contractual options, or potentially can use commercial leverage, to seek a refund of some or all of the price increases.

Importers of record need to ensure they are best positioned to secure any refunds, while also adapting to the new replacement tariffs. Therefore, on the customs side, we recommend the following steps for importers of record dealing with these issues.