Tariff Refunds Are Real: What Your CFO Should Be Doing Right Now

CFO Dive recently reported that finance leaders are expected to play a central role in steering their organizations through this process, which is set to launch imminently. For large companies with dedicated tax and trade counsel, that's a manageable lift. For the $3M to $75M revenue businesses that make up the lower middle market, it's a different story — the workload is real, the documentation requirements are specific, and most don't have a CFO in the building to own it.

That's exactly the problem Pyek Financial works with clients to solve. The tariff refund process isn't simple, but it is manageable — if someone with the right financial and operational lens is running point.

What Is the Tariff Refund Process, and Who Actually Qualifies?

Not every company that paid tariffs will get money back. The refund mechanism here is largely tied to Section 301 exclusions — specific product classifications where the U.S. Trade Representative (USTR) has granted relief — as well as certain duty drawback programs administered by U.S. Customs and Border Protection (CBP). Eligibility depends on the Harmonized Tariff Schedule (HTS) codes for your imported goods, when the goods entered the country, and whether a valid exclusion was in place at the time of entry.

The exclusion process has been inconsistently administered since 2018. Some exclusions expired, were retroactively reinstated, and then lapsed again. If you're a manufacturer or distributor who imported goods during any of those windows, your finance team needs to go back through entry records and match them against active exclusion periods — not just current status.

This is detail work. It requires pulling CBP entry summaries, cross-referencing HTS codes against USTR exclusion lists, and understanding the relevant filing windows. A bookkeeper can't do this. A generalist controller probably shouldn't be doing it alone.

Why SMBs Are the Least Prepared for This

Large companies have trade compliance teams. Most SMBs don't even have a CFO. That gap matters here because the tariff refund process sits at the intersection of financial records, customs documentation, supply chain data, and regulatory filing — four systems that rarely talk to each other cleanly.

For example, a $12M wholesale distributor could have paid six figures in Section 301 duties over a two-year period. Not finding out whether or not exclusions applied. The entry records exist inside their customs broker's system. Their internal books would show landed costs, not duty line items. Connecting those two data sets and identifying potentially refundable amounts would require someone who understood both the financial statements and the customs process. That work doesn't happen without a CFO-level function pushing it.

The cost-benefit case is straightforward. If your company imported goods in affected categories between 2018 and now, potential refunds could range from tens of thousands to several hundred thousand dollars depending on volume. The filing process has a cost, but it's almost always justified by the potential recovery.

The Four Things a CFO Needs to Manage This Process

There's no mystery about what good execution looks like here. The work falls into four categories:

1. Eligibility assessment. Pull your HTS codes for all imported goods, cross-reference against current and retroactive USTR exclusion lists, and identify which entries fall within eligible windows. If you don't have your HTS codes memorized, your customs broker does. Get them on the phone this week.

2. Documentation assembly. CBP requires entry summaries (CBP Form 7501), commercial invoices, and proof of payment for each entry you're claiming. If you used a customs broker, most of this exists in their system. If you self-filed, you'll need to go back through your own records. Missing documents are the most common reason claims get delayed or denied.

3. Financial impact modeling. Before you file, you need to know what you're likely to recover and when. Refund timelines through CBP are not fast. Cash flow implications matter. If you're expecting $80,000 back but it won't arrive for 12 to 18 months, your CFO should factor that into your working capital model — not just log it as accounts receivable and move on.

4. Filing and follow-through. The actual claim submission goes through CBP's Automated Commercial Environment (ACE) portal, typically via your customs broker. But someone on your side needs to manage the process, track status, and respond to any CBP requests for additional information. That follow-through is where most SMBs drop the ball.

What to Do If You Don't Have a CFO In-House

If your company is between $3M and $75M in revenue and you're running without a CFO, you're not unusual. A full-time CFO runs $300,000 or more when you factor in salary, bonus, and benefits — and most companies in this range don't need that overhead on a permanent basis. What they do need is CFO-level thinking when the work demands it.

The tariff refund process is exactly that kind of moment. It's time-bounded, high-value, and requires coordination across finance, operations, and external advisors. A fractional CFO can own this project end-to-end: assess eligibility, work with your customs broker, build the cash flow model, manage the filing, and report back to ownership on status and expected recovery.

Don't mistake this for a job that belongs in accounting. Your bookkeeper tracks what was paid. Your fractional CFO decides what you should get back — and builds the process to get it.

The Window Is Open. Someone Needs to Own It.

The companies that recover meaningful dollars from this process will be the ones that put a capable financial leader on it now. This isn't a task that works well assigned down the org chart. CBP is not forgiving of incomplete submissions, and filing windows don't extend for companies that weren't ready.

If you don't have someone in-house who can own this, Pyek Financial offers fractional CFO engagements built for exactly this kind of project. No retainer required to start a conversation.

The money is there. The question is whether your finance function is positioned to go get it.