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The Billion-Dollar Wait: Navigating Post-Ruling Tariff Refunds Why recent legal victories for Texas importers may face a long, complex road to actual reimbursement. Overview Following a landmark U.S. Supreme Court ruling that more than $126 billion  in emergency tariffs were collected illegally, the U.S. Court of International Trade has ordered the administration to begin refunds. While U.S. Customs and Border Protection aims to begin processing these claims within 45 days, legal experts warn that the process will be neither swift nor simple. March 9, 2026 " Texas businesses could wait years for tariff reimbursements — if they come at all — despite court rulings . " Publication: Houston Public Media PBS / NPR The Challenge of Recovery While the judicial path has cleared, the administrative hurdles remain significant. Importers must weigh the benefit of a refund against the potential for increased government scrutiny. Michelle Schulz , a Dallas-based trade attorney, highlights a critical risk for businesses entering the refund system: "They will have a system whereby they’ll refund your money. The problem is, Customs is also going to be looking in that same system to see if you made any mistakes, and they can go back five years." - Michelle Schulz As the administration signals potential shifts toward new 15% global tariffs under different statutes, the actual long-term impact of these hard-won refunds remains to be seen. Protect Your Compliance Record While Seeking Redress. Navigating the refund process requires a clean five-year audit trail to avoid unexpected liabilities. Contact Schulz Trade Law today  to review your records before you file for reimbursement. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

Navigating the Ripple Effects: Global Trade and the Iran Conflict The Hidden Costs of Disruption in the Strait of Hormuz Overview The current tensions in the Middle East have sent tremors through the global supply chain, extending far beyond the gas pump. As conflict disrupts one of the world's most critical maritime arteries—the Strait of Hormuz —importers and exporters face a complex landscape of rising costs and logistical hurdles. International trade attorney Michelle Schulz recently joined This Morning with Gordon Deal  to break down what this means for businesses and consumers alike. March 6, 2026 This Morning with Gordon Deal Gordon Deal Show Host: Gordon Deal While energy prices often dominate the headlines during Middle East (Iran) conflicts, the economic impact is much broader. The Strait of Hormuz is a vital transit point for a significant portion of the world's petroleum and liquefied natural gas. However, as Michelle Schulz points out, the "ripple effect" hits manufacturing and consumer goods almost immediately. The Plastic and Production Squeeze The cost of raw materials is intrinsically linked to energy stability. Because plastics are derived from petroleum and natural gas, any disruption in the Strait quickly translates to higher production costs for everything from household goods to industrial components. "Plastics are based around oil or natural gas. Heating, air conditioning, cooking—all that stuff gets more expensive when there's a shortage... anything surrounding the oil and gas industry is also going to be impacted." — Michelle Schulz Logistics and the "Plan B" Reality For companies moving goods through the region, the choice is often between high-risk transit or expensive, time-consuming detours. Safety concerns for personnel and cargo are forcing many to implement secondary logistics strategies, such as rerouting around the Cape of Good Hope. "They have to consider whether they will wait, whether it's safe for their personnel to go in those areas... they're having to reroute, and they have different routes that they pursue. They do have to make longer hours for pilots, extra jet fuel... you'll see higher shipping bills." — Michelle Schulz The Shifting Regulatory Landscape Beyond physical logistics, the legal and regulatory environment is equally volatile. Sanctions and political instability can change the viability of trade agreements and export licenses overnight, requiring businesses to be more agile than ever. "Depending on the political situation, you may or may not get your license approved. That can change from day to day... We will definitely change our advice to clients depending on the situation at the time." — Michelle Schulz Is Your Supply Chain Prepared? In a global economy, local conflicts rarely stay local. Whether you are dealing with increased shipping bills, licensing delays, or the need for alternative sourcing, having a robust legal and logistical strategy is essential. Don't wait for the next disruption to secure your trade routes.   Contact Schulz Trade Law today to review your export licenses and develop a resilient "Plan B" for your global operations. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

Resource Article Recent Export Penalties and How to Avoid Them Ashlyn Koenig Smith, Schulz Trade Law PLLC Feb 24, 2026 Download this Article An Export Administration Regulations (EAR) violation can result in penalties "of up to 20 years of imprisonment and up to $1 million in fines per violation, or both.” [1]   Export violations are widely publicized, so it is paramount to stay current on recent export enforcement to avoid penalties and understand the latest trends in enforcement. Thus, we will explore two EAR violations and the penalties that followed, according to recent publicly available knowledge. We will also touch on general trends in penalty violations from court orders of the last six months, and red flags to look out for in transactions   that may require EAR licensing. Schulz Trade Law offers a library of Trade Law Resources. Download this article Recent EAR Violations: Between November 8, 2020, and July 18, 2022, Applied Materials Inc ., a semiconductor manufacturing equipment company based in California, and its subsidiary, Applied Materials Korea, based in South Korea, allegedly reexported or attempted to reexport items subject to the EAR without the proper licensing on fifty-six occasions, according to a court order released on 2/11/26. This was done even though they were informed by the Bureau of Industry and Security (BIS) that they were required to do so when exporting or reexporting ion implanters, which are semiconductor materials, to SMIC Subsidiaries. Specifically, they violated 15 C.F.R. § 764.2(a) – Engaging in Prohibited Conduct and 15 C.F.R. § 764.2(c) – Attempting to Engage in Prohibited Conduct. The company settled and agreed to pay a fine of $252,500,300 , one of the largest fines the agency has issued thus far, and the maximum fine allowed by the Export Control Reform Act of 2018. It must also complete two internal audits of its export controls compliance program. If the company failed to abide by the conditions of the settlement, it could lose export privileges for three years. [2]   Secondly, in October of 2022, Luminultra Technologies , located in Linthicum Heights, Maryland, allegedly sent PhotoMaster luminometers and aqueous test kits to Iran, forgoing the required licensing as set out in 15 C.F.R §746.7(e). A court order released on 09/30/2025 alleged that the company knew that Iran was its product's ultimate end-user, and that this violated EAR licensing requirements, but went ahead with the sale regardless. Ultimately, Luminultra and BIS agree to settle. The company had to pay a fine of $685,051 . It was also ordered to complete an export compliance audit for 2025 and for each of the next three years, and all employees had to complete export compliance training. If the company failed to abide by the conditions of the settlement, they would be subject to lose export privileges for three years. [3]   Trends In addition to the aforementioned violations, several other EAR penalties issued between September 2025 and February 2026 had to do with firearms, their parts, accessories, and ammunition, as well as airplane parts. Many of the times, these products were sent to Russia, China, South American countries, and Middle Eastern countries. However, as the Luminultra violation demonstrates, companies should not assume that only such products require EAR licensing. Likewise, it should not be assumed that only those sending products to the aforementioned countries require licensing. Rather, companies need to be aware of their products' end users and final destinations.   Red Flags This is because potential license violations depend on one’s knowledge of the end use of their products. However, this does not mean companies or firms should intentionally blind themselves to potential red flags by discouraging buyers from sharing certain information, as this, too, may lead to penalties. Instead, the EAR highly encourages businesses and firms to become familiar with its extensive list of red flags one should be aware of when considering whether or not a product will end up in the appropriate end-user destination. [4]   Some of which include: 1 The product does not align with the buyer’s business. For instance, an aquarium attempts to order complex commercial airplane parts. 2 A buyer offers to pay cash for an expensive product when it’s typically paid for via financing. 3 The buyer evades questions concerning whether the product is for domestic use, export, or reexport. 4 A buyer declines routine installation, training, or maintenance services of a product he’s seeking to purchase. 5 A buyer wants a highly technical product shipped to a country that does not have an industry to support it. For instance , a buyer ordering semiconductor parts to a country without an electronics industry. If you have encountered a red flag, do not ship the product until it is resolved. It's generally advisable to hold the export and seek further guidance.   Conclusion While recent trends in enforcement such involving enforcement tend to involve semiconductors, firearms, and aviation, as well as countries like Russia, China, and those in the Middle East and South America, this article only scratches the surface of EAR licensing, penalties, and violations. To avoid EAR penalties, companies must be vigilant when assessing the ultimate end use of their product. For further assistance in navigating the EAR, contact one of the trade attorneys at Schulz Trade Law PLLC   [1]   Export Control Reform Act of 2018,  50 USC §§ 4801-4852 (2018). [2]   Order Relating to Applied Materials Inc. and Applied Materials Korea,  U.S Department of Commerce, Bureau of Industry and Security, February 11, 2026, 2-4,14-16. [3]   Order Relating to Luminultra Technologies Inc., U.S Department of Commerce, Bureau of Industry and Security, September 30, 2025,1-9. [4] 15 CFR §732 Supplement No. 3, (2026). Resource Library Learn more about Trade Law. We have a series of articles highlighting the key components of international trade and compliance. Contact Us Stay ahead of trade law changes! Contact us today for guidance on tariffs and regulations to safeguard your business.

Navigating the New Era of Trade The Founder of Schulz Trade Law shares insights on Supreme Court shifts, the 15% global tariff threat, and why "expecting the unexpected" is the only strategy for 2026. Overview In the wake of landmark judicial rulings and a rapidly shifting executive approach to international trade, businesses are facing an unprecedented administrative burden. Michelle Schulz, Founder and Managing Partner of Schulz Trade Law PLLC, has spent over two decades guiding Fortune 500 companies through these exact types of regulatory storms. In this exclusive interview, Michelle breaks down the legal complexities of 2026, from the "major questions" doctrine to the tactical necessity of supply chain diversification. Feb 23, 2026 The Briefing with Steve Scully SiriusXM POTUS Host: Steve Scully The Judicial Shake-up and Tariff Refunds The start of 2026 has been defined by the Supreme Court’s decision to strike down emergency tariffs, leaving billions of dollars in duties in limbo. For importers, the question isn’t just about future strategy—it’s about recovering what was already paid. Michelle emphasizes that while the legal victory is significant, the path to a refund is far from a straight line. "The status of billions in duties remains in limbo. For many companies, the administrative burden of tracking and reclaiming these funds is extraordinary. To grow in a healthy way, leading companies are reevaluating the regulatory landscape and scaling up their compliance programs to meet these demands." The Reality of "Trump II" and Global Tariffs With the administration pivoting toward a 15% global import tax and citing new legal authorities, the cost of doing business is shifting overnight. Michelle highlights that these policies aren't just numbers on a balance sheet—they have a direct, compounding effect on everything from raw materials to consumer-facing prices. "When you think about the staggering scale of these tariffs—sometimes reaching triple digits in specific sectors—the cost will inevitably be passed down. You have to expect the unexpected; any country with a trade surplus is now an area where the government may look to offset that imbalance." Strategic Compliance in a Volatile Market For Michelle, the solution isn't just reacting to news—it's building a resilient infrastructure. Whether it’s navigating the UFLPA, country-of-origin rules, or EAR/ITAR licensing, she advocates for a proactive "solution-focused" approach that treats compliance as a competitive advantage rather than a hurdle. "There is going to be a transition period before new infrastructure is in place. Companies must adopt trade compliance programs that minimize legal risks while promoting growth. It’s about more than just checking boxes; it’s about strategic import and export decisions in real-time." Don’t Navigate These Shifting Currents Alone.   With new tariffs being announced and judicial rulings changing the game, your business needs more than just legal advice—it needs a strategic partner. Contact Schulz Trade Law to schedule a consultation and ensure your compliance program is ready for the challenges of 2026. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

The Future of Tariffs:  Navigating the Supreme Court’s Recent Ruling and What It Means for Your Business Unpacking the legal shift in trade policy, the 15% workaround, and the fight for $175 billion in tariff refunds. In a landmark decision that has sent shockwaves through the global trade community, the Supreme Court recently ruled 6-3 that certain tariffs implemented by the executive branch were illegal. The court’s message was clear: the power to levy tariffs belongs to Congress, not the President. This ruling has left $175 billion in collected revenue hanging in the balance and sparked a new executive order aimed at a 15% tariff "workaround." To help make sense of this legal whirlwind, trade law expert Michelle Schulz  of Schulz Trade Law joined WLW Radio’s Scott Sloan to discuss the implications for businesses, consumers, and the future of international trade. Feb 23, 2026 WLW Radio Cincinnati Host: Scott Sloan The Power Shift: Why the Supreme Court Sided with Congress The core of the Supreme Court's ruling rests on the separation of powers. For decades, the executive branch has utilized specific trade laws—such as the International Emergency Economic Powers Act (IEEPA)—to implement tariffs. However, the court has now drawn a hard line, stating that unilateral implementation overstepped constitutional boundaries. "This is not your job. This is a job of Congress," Michelle explains, summarizing the court's definitive stance. "The power to tax and the power to set tariffs is a Congressional power, and the President can't just take it under the guise of an emergency." The $175 Billion Question: Will Companies Get Their Money Back? With the Supreme Court declaring the IEEPA tariffs illegal, the immediate question for many businesses is: What happens to the money we already paid?  Currently, the U.S. Treasury is sitting on approximately $175 billion in revenue collected under the now-invalidated rules. "It’s not an automatic refund," Michelle warns. "Companies have to be proactive. If you haven't filed a protest or a claim, the government isn't just going to mail you a check. You have to go after it legally." The 15% Workaround and the Impact on Your Wallet The legal victory for opponents of the tariffs was short-lived. In response to the ruling, the administration pivoted to Section 122 of the Trade Act, implementing a 15% "surcharge" as a workaround. This ensures that trade tensions—and the resulting costs passed on to consumers—remain high. "We’re in a game of legal Whac-A-Mole," says Michelle. "One door closes and the administration opens another. For the business owner, it means the 15% is still there, just under a different name, and you have to adjust your pricing all over again." Take Action: Is Your Business Owed a Refund? The Supreme Court ruling has opened a narrow window for companies to seek redress for illegally collected tariffs. Don't leave your hard-earned capital in the hands of the Treasury. If your business has been impacted by recent tariff hikes, you need expert guidance to determine your eligibility for a refund and to navigate the new 15% executive order. Contact Schulz Trade Law today to protect your bottom line. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

The SCOTUS Ruling: A Shift in the Tariff Landscape and What Lies Ahead Understanding the Rejection of Emergency Powers and the President’s Next Move In a landmark decision that sent ripples through Wall Street, the Supreme Court has officially struck down the use of emergency powers to impose global tariffs. While the markets responded with a 200-point surge in the Dow , the legal battle over international trade is far from finished. Feb 20, 2026 Fox 5 New York Host: Antwan Lewis Following the ruling, the administration has already signaled its intent to bypass the court’s decision by utilizing alternative federal statutes. Here is a breakdown of the ruling and the new "avenues" currently being explored. The Constitutional Conflict: Congress vs. The President The Supreme Court ruled that the administration violated federal law by claiming emergency powers under the 1977 International Emergency Economic Powers Act (IEEPA)  to bypass Congress. The justices emphasized that the Constitution clearly grants the power to impose taxes and tariffs to Congress, not the executive branch. "The justices in the majority found that the Constitution very clearly gives Congress the power to impose taxes."  — Antwan Lewis Alternative Avenues: Section 232 and Section 301 Despite the ruling, the administration argues that other statutes—specifically Section 232  and Section 301 —provide the necessary authority to keep tariffs in place or even expand them. Section 232 (Trade Expansion Act of 1962):  Used to justify tariffs based on national security concerns, potentially allowing for an across-the-board 10% tariff on goods. Section 301 (Trade Act of 1974):  Allows for investigations into "unfair trade practices," which can lead to targeted tariffs after a formal request and investigation. Market Reaction and Global Implications While traders initially cheered the SCOTUS decision, the promise of new tariffs has introduced a fresh layer of uncertainty for US trade partners and manufacturers. The administration remains firm that these actions are necessary to address trade imbalances and international drug trafficking, regardless of the court's recent holding. "The decision might not substantially constrain a president's ability to order tariffs going forward... numerous other federal statutes authorize the president to impose tariffs."  — Donald Trump The Presidential Trade Arsenal: A Comparative Look As the administration moves away from the now-invalidated IEEPA (International Emergency Economic Powers Act), they are turning to more structured—but still potent—statutory "hammers." Authority Legal Trigger Implementation Speed Duration & Limits Section 122 "Large and serious" balance-of-payments deficits. Immediate.  No investigation required. Capped at 15%  for 150 days  (unless extended by Congress). Section 232 Imports that "threaten to impair" national security . Slow.  Requires 270-day Commerce Dept. investigation. No limit  on tariff rate or duration once implemented. Section 301 "Unjustifiable or unreasonable" unfair trade practices . Slow.  Requires 12–18 month USTR investigation. No limit  on tariff rate; must be reviewed every 4 years. Navigate the Evolving Trade Climate with Schulz Trade Law The rules of the game are changing rapidly. Whether you are seeking a refund from the struck-down IEEPA tariffs or preparing for upcoming Section 301 investigations, you need a legal partner who understands the nuance of executive authority. Is your supply chain protected against the next wave of tariffs?   Contact Schulz Trade Law  today for a compliance audit and strategic consultation Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

The SCOTUS Tariff Ruling: Why the Battle for Free Trade is Just Beginning How the Administration is Pivoting to New Statutes After a Major Legal Defeat The U.S. Supreme Court has delivered a significant blow to executive overreach in international trade. By striking down global tariffs imposed under emergency powers, the Court has reasserted that the power to tax remains with Congress . However, as the Dow surges 200 points in response to the news, a new era of trade uncertainty is already unfolding. International trade attorney Michelle Schulz joined KNX Radio and Fox 5 New York to explain why importers should temper their celebrations with strategic preparation. Feb 20, 2026 KNX Radio Los Angeles The Constitutional Rejection of IEEPA The nation’s highest court ruled that the administration broke federal laws by claiming emergency powers under the 1977 International Emergency Economic Powers Act (IEEPA) . The ruling clarified that the President cannot unilaterally levy reciprocal taxes on nearly every trading partner without Congressional approval. "The justices in the majority found that the Constitution very clearly gives Congress the power to impose taxes."  — Antwan Lewis, Reporting on the SCOTUS Decision The New Arsenal: Section 232 and Section 301 Despite the ruling, the administration is vowing to use "other avenues" to keep tariffs in place. This includes a pivot to alternative federal statutes that do not require an emergency declaration but still allow for significant trade barriers: Section 232 (Trade Expansion Act of 1962):  Used to justify an across-the-board 10% tariff on goods based on national security. Section 301 (Trade Act of 1974):  Allows for investigations into "unfair trade practices," which could lead to additional, targeted tariffs. "The President can legally impose tariffs under different laws even if businesses would rather not see that happen."  — Michelle Schulz Importer Frustration and the "Complex" Path to Refunds While the SCOTUS decision offers hope for reclaiming past payments, Michelle Schulz warns that the refund process for IEEPA-related tariffs will be "complex and nuanced". Many importers remain frustrated, as they continue to face penalties for non-payment while navigating a system that may soon be hit with a fresh wave of secondary tariffs. "There may be refunds available on these IEEPA tariffs, but importers should keep in mind that that could take a very long time."  — Michelle Schulz Is Your Business Prepared for the Next Wave? The "emergency" may be over, but the era of high tariffs is simply changing shape. Whether you are seeking a refund for previous IEEPA payments or need to prepare for upcoming Section 301 investigations, expert legal counsel is essential. Schulz Trade Law  is currently assisting clients in navigating these new statutory hurdles. Contact us today. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

New Tariffs and Refund Chaos: What Businesses Need to Know After the Supreme Court Ruling Navigating the shift from invalidated duties to Section 122 enforcement and the long road to recovery. Overview: The trade landscape shifted dramatically this morning following a landmark Supreme Court decision that invalidated a significant round of tariffs. While many U.S. businesses are celebrating the prospect of recovering billions in duties, the celebration may be short-lived. The administration has already signaled a pivot to new trade enforcement measures, and the path to securing refunds promises to be a complex, uphill battle. Feb 20, 2026 Fox 26 / KRIV TV Houston Host: Tom Zizka Here is a breakdown of what this ruling means for your bottom line and how the government plans to maintain its tariff strategy. The Multi-Billion Dollar Refund Reality The Supreme Court’s decision has invalidated tariffs that accounted for anywhere from $130 billion to $200 billion in collected revenue. While these specific tariffs "go away" as of today, businesses should not expect a windfall overnight. The process for claiming these refunds has been on hold pending this decision, and the sheer volume of anticipated claims is expected to create a massive administrative backlog. For businesses in high-volume sectors like Houston’s oil and gas industry, the wait for capital to return to their accounts could be extensive. The Section 122 "Backup Plan" The administration was prepared for this ruling. Almost immediately following the decision, the President responded by invoking new tariffs under different sections of trade law— specifically Section 122 . This provision serves as a strategic bridge. It allows the administration to keep tariffs in place for 150 days (roughly 5 months). This window provides the government enough time to conduct necessary investigations and transition the tariffs into other long-term provisions of the trade code. Essentially, while the legal justification has changed, the financial burden on importers remains largely the same. Anticipating a Chaotic Recovery Process Trade experts warn that the transition between tariff regimes will be far from seamless. As the new executive order takes effect within three days, businesses relying on foreign goods will find themselves writing checks for new tariffs even as they struggle to claw back the old ones. Michelle Schulz of Schulz Trade Law emphasizes that the complexity of the refund process cannot be understated. Drawing on her experience with complex trade mechanisms, she notes: "My experience with refunds, for example in duty drawback which is often used in oil and gas in Houston, is that it can take months if not years to get your refund. There will be so many refund requests; I anticipate it's going to be a bit chaotic." Furthermore, Schulz warns that while Section 122 is a temporary measure, the legal framework allows for a much longer game: "This is temporary, but there are other much longer-term provisions under which [the President] can continue tariffs. This could drag out for a very long time." Protect Your Interests Today With hundreds of billions of dollars at stake and a "chaotic" refund process on the horizon, businesses cannot afford to take a passive approach. Navigating the intersection of Section 122 investigations and refund claims requires aggressive legal oversight. Contact Schulz Trade Law today to ensure your claims are filed correctly and your business is prepared for the next round of trade enforcement. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

Billions in Potential Tariff Refunds Following Landmark SCOTUS Ruling DALLAS, TX  — Following a monumental Supreme Court decision that has sent shockwaves through the global trade community, Michelle Schulz , founder of Schulz Trade Law, appeared on Fox 4 to provide critical guidance for U.S. importers. Feb 20, 2026 KDFW-TV/Fox 4 Dallas-Fort Worth Host: Shaun Rabb The ruling, which voided significant portions of the administration’s sweeping tariff policies, has opened the door to potential refunds of  $133 billion to $175 billion . However, as Schulz warned viewers, the road to recovery is paved with regulatory hurdles. "Dot Your I’s and Cross Your T’s" During the segment, Schulz emphasized that the federal government will not simply issue checks to every business that paid the now-voided duties. Instead, the burden of proof rests on the companies to navigate a complex, technical protest process. "They need to make sure they understand import compliance and that they understand how their duties are calculated,"  Schulz told Fox 4. "It's very important to dot your i's and cross your t's in this situation where you're asking for money back." Why Precision is Non-Negotiable For many businesses, these tariffs—often ranging from 10% to 25%—have significantly impacted bottom lines and consumer prices. Reclaiming that capital requires a three-pronged approach: Rigorous Audit:  Verifying every HTS code and duty calculation. Compliance Verification:  Ensuring past import records meet federal standards to prevent secondary audits. Strategic Filing:  Navigating the specialized Court of International Trade to ensure claims are prioritized. Is Your Business Eligible for a Refund? Don't let administrative complexity prevent your company from recovering unlawfully collected duties. The window to file protests is limited. Contact Schulz Trade Law today  for a comprehensive evaluation of your tariff exposure and recovery options. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.

Navigating the Post-Trump Tariff Refund Landscape: Expert Advice from Michelle Schulz Dallas Trade Law Expert Explains How Companies Can Secure Refunds on Unconstitutional Duties Overview:   The international trade world recently experienced a seismic shift. With the Supreme Court deeming significant portions of the Trump administration’s tariff policies void, thousands of U.S. companies may now be eligible for substantial refunds. However, reclaiming those tariff refunds isn't as simple as sending an invoice to the government. Feb 20, 2026 Your Money Now Compass Networks Host: Dan Loney In a recent interview on Your Money Now , Michelle Schulz , founder of Schulz Trade Law  and a leading expert in international trade litigation, laid out the roadmap for businesses looking to recover their duty payments. The Path to Recovery: Precision and Compliance As Schulz points out, the burden of proof rests entirely on the importer. When the stakes involve federal refunds, the government’s scrutiny is at an all-time high. "It's very important to dot your i's and cross your t's in this situation where you're asking for money back," Schulz noted. To successfully navigate this process, Schulz identifies two critical pillars for any recovery strategy: Deep-Dive Import Compliance:  Before filing a claim, companies must ensure their entire import history is beyond reproach. Any existing compliance gaps could not only jeopardize a refund but potentially trigger an unwanted audit. Granular Duty Calculation:  Understanding exactly how your duties were calculated—and where the specific voided policies applied—is essential. Accuracy in these technical calculations is the difference between a successful claim and a rejected one. Don't Leave Money on the Table The complexity of trade law means that many companies may not even realize the full extent of the refunds they are owed. The transition from policy to litigation to actual recovery requires a meticulous, legally-sound approach. Take Action: Secure Your Trade Audit Today Is your business positioned to recover its miscalculated duties? Don't let administrative complexity stand between your company and its rightful capital. Contact Schulz Trade Law  to schedule a comprehensive tariff recovery consultation. Our team of experts will help you audit your compliance, recalculate your duties, and ensure every "i" is dotted and every "t" is crossed. Schedule your consultation and protect your bottom line.

Updates on (Automation) Updates: CBP Electronic Refunds and Electronically Submitted VSDs Ashlyn Koenig Smith, Schulz Trade Law PLLC updated: Feb 20, 2026 Download this Article In the fast-paced world of International Trade, companies must stay informed about the latest updates to the multitude of rules and regulations to avoid delays, fines, and penalties that hinder business. This article will cover recent changes to automation concerning U.S. Customs and Border Protection’s (CBP) new electronic refund process, and Voluntary Self-Disclosures (VSDs). It will highlight what you need to know about these changes and who needs to take action to keep your business up to date. Schulz Trade Law offers a library of Trade Law Resources.   Electronic Refunds Update On February 20th, 2026, the U.S. Supreme Court ruled that President Trump could not use emergency powers to impose tariffs. This could lead to substantial refunds on tariffs paid since President Trump dubbed “Liberation Day.” While the refund process may be lengthy, CBP’s recent update on electronic refunds is meant to make it smoother. Beginning February 6th, 2026, CBP will issue all refunds electronically via Automated Clearing House (ACH). [1] You must ensure you are enrolled in the Electronic Refund system, as it is now up-and-running. If you currently receive ACH refunds: You don’t have to reenroll, but you should double-check that your information is accurate. If you don’t already receive electronic refunds via ACH: You must register for an Automated Commercial Environment Secure Data Portal (ACE Portal) to receive electronic refunds. Click here  for further information. If you don’t have a CBP Form 5106 on file, you must submit a CBP Form 5106 or have a customs broker submit an electronic CBP Form 5106. If you have a CBP Form 5106 on file, you must submit the modernized application webform. If you have a current CBP Form 4811 on file that authorizes a broker to receive refunds: You should ensure that the “4811 notify party” permits the broker to receive ACH refunds. Effective February 6, 2026. If you need to add or modify a notify party , use the recently updated CBP Form 4811 . The previous version of the form is no longer accepted. You can find the new form here  by searching for the form number. CBP also notes that the bank you direct your refunds to must be able to process FedACH payments. For more information about electronic refunds, visit  here .   Voluntary Self-Disclosures (VSDs) Updates On February 6, 2026, the Office of Foreign Assets Control ( OFAC ) launched a new portal for VSDs that is up and running. [2] To view the OFAC's new portal and learn more, visit this website . Additionally, since January, 2024, the Bureau of Industry and Security (BIS) has encouraged VSDs pertaining to violations of the Export Administration Regulations (EAR) to be submitted via email. [3]  This process differs from the online portal SNAP-R, which only handles export and import licensing pertaining to commodities, software, technology, and activities subject to the Export Administration Regulations (EAR), 15 C.F.R. parts 730-774. While neither agency requires electronic submission of VSDs, they are highly encouraged over paper submission as they streamline the entire process, making it easier for their users. In short, CBP's recent switch to electronic refunds and automation updates to VSDs is meant to ease the trading process. However, businesses must stay up-to-date about such changes for maximum efficiency. Ready to update your compliance strategies with the latest CBP automation changes? For further assistance in navigating the vast complexities of international trade law, contact  expert attorneys at Schulz Trade Law . [1]  U.S Customs and Border Protection, 91 FR 21, (2025). [2]  U.S Department of the Treasury, Launch of Voluntary Self-Disclosure Portal,  (2026), https://content.govdelivery.com/accounts/USTREAS/bulletinsthe/4082377 . [3]  U.S. Department of Commerce, Assistant Secretary for Export Enforcement, Memorandum for All Export Enforcement Officials , Washington D.C., (2024). Resource Library Learn more about Trade Law. We have a series of articles highlighting the key components of international trade and compliance. Contact Us Stay ahead of trade law changes! Contact us today for guidance on tariffs and regulations to safeguard your business.

SCOTUS Strikes Down Global Tariffs: What Importers Need to Know Now Navigating the Path to Refunds in the Wake of the Supreme Court’s Landmark Decision The landscape of international trade shifted dramatically this past Friday. In a long-awaited ruling, the Supreme Court of the United States struck down the majority of President Trump’s global tariffs . While the decision brings a wave of optimism to the trade community, the road to financial recovery is paved with complex administrative hurdles. Feb 20, 2026 This Morning with Gordon Deal Host: Gordon Deal Michelle Schulz , International Trade Attorney and founder of Schulz Trade Law, joined This Morning with Gordon Deal  to break down the ruling and provide a roadmap for businesses seeking to reclaim their funds. Immediate Impact vs. Long-term Recovery While the collection of these tariffs was expected to cease immediately following the Friday ruling, the refund process is far from instantaneous. Schulz warns that while the legal victory is significant, the logistics of returning capital to businesses will be "a bit of a chaotic process". "The collection of tariffs should stop immediately. However, refunds are going to be a different story... I think it’s going to be months, if not longer."  — Michelle Schulz The Digital Hurdles of the Automated Commercial Environment Refunds will be processed electronically through the Automated Commercial Environment (ACE) . For importers, this means technical readiness is just as important as legal standing. Businesses must ensure they are properly registered and that their import data is meticulously organized to facilitate claims. "Importers need to be set up in the electronic system and ready to go with their claims. It’s not always easy from a techie perspective—you have to do your homework there."  — Michelle Schulz Avoiding the "Defensive": Record Keeping and Compliance With Customs currently in a high-enforcement mode, Schulz emphasizes that "getting your ducks in a row" is a matter of survival, not just administration. Customs requires a five-year record-keeping period , and any gaps in documentation could lead to seizures or penalties rather than refunds. "If you are not prepared and if you don’t have five years of import records, you could find yourself on the defensive."  — Michelle Schulz Get Started on Your Refund Claim Today The Supreme Court has opened the door, but it is up to your business to walk through it with the right data and legal strategy. At Schulz Trade Law , we are currently auditing import data for our clients to calculate exact owed amounts and file proper claims. Don't leave your capital in the government's hands.   Contact Schulz Trade Law today to ensure your records are compliant and your refund claims are filed accurately. Trade on, but trade informed! Subscribe  to Schulz Trade Law for more updates.