The Tamesis
Pagan was ruthless about the basic principle: The government was not eligible for the money in the first place. But there’s a huge gulf between having a legal right to a refund and actually getting one.
For fashion houses, it is imperative to take immediate action before the process is formalized. Santos advises customers to file a protest immediately to preserve their right to a refund, retain all documentation related to IEEPA duty payments—import data, entry summaries, payment records, invoices and any CBP correspondence—and carefully track inventory liquidation dates. “We are helping many companies evaluate their import data and apply for refunds quickly once processes are developed,” she said.
Business pressure is great. Chris Desmond, partner in PwC’s customs and international trade practice, warned that the refund process would be carried out on top of an already stretched customs infrastructure. “Customs brokers will be under tremendous pressure and have limited ability to respond to the surge of post-aggregation corrections and protests from thousands of importers,” he said. “As refund mechanisms take shape, those companies that move quickly, have clear data and a clear strategy will be better positioned to get ahead.”
Desmond recommends that companies focus on three key priorities: robust modeling of real opportunities and qualifications at the entry level; CFO-level focus on refund timing relative to seasonal cash needs; and an honest accounting of execution risk.
There is also a downstream contract issue. Santos noted that companies that restructured supplier relationships, renegotiated contracts or explicitly adjusted pricing in response to IEEPA tariffs may now face disputes over those arrangements. She said significant change provisions and any clawback mechanisms related to tariff changes should be reviewed immediately.
Ali Furman, consumer markets industry leader at PwC, raised the issue of chargebacks in a way that will resonate with finance teams: Any chargebacks received before the cash is received are likely to be viewed as a one-time gain rather than as structural profit normalization. “Strategic decisions then become capital allocation,” she said—whether to reinvest in the brand and retail experience, strengthen inventory positions ahead of key seasons, or improve price positioning in competitive categories. She warned that, especially for luxury brands, any changes to pricing structures must be weighed against long-term brand equity signals.
If brands are raising prices citing IEEPA tariffs, the question of whether they will now reverse those increases isn’t as simple as it seems – and the answer from some analysts is: not yet, and probably not at all.
Neil Saunders, managing director of retail at GlobalData, is blunt about consumer expectations: Most shoppers already view rising prices as the new normal. “Consumers are fed up with inflation, so any price reduction will be welcomed,” he said. “However, most people have accepted that prices will remain high.” In theory, the market could punish brands that maintain high pricing after the ruling, but in practice, he noted, few consumers would be willing to take on the task of linking tariff-driven price increases to broader inflation adjustments.
Furman makes a point closer to brand reputation than profit: Companies that indiscriminately raise prices during tariff periods may face pressure to prove that refunded tariffs benefit the customers who bear those costs. “Retailers can use refunds to offset previous price increases through targeted promotions and/or offering one-off employee bonuses,” she said. How brands handle this calculation—whether by absorbing costs to protect customers or passing costs indiscriminately—may prove to be as important to long-term loyalty as the tariff risk itself.
Diversification is irreversible
One of the most important shifts in the IEEPA tariff era is procurement. Dr. Lu Sheng, director of the Department of Fashion and Apparel Studies at the University of Delaware, said that China’s share of U.S. apparel imports will drop from 20.9% in 2024 to 13.7% in 2025 – this is a structural change directly driven by tariff pressure. U.S. fashion companies are actively turning to emerging suppliers in Cambodia, Pakistan, Jordan and Sri Lanka, while overall U.S. apparel import growth lags significantly behind peer markets: only 1.7% growth in the first 10 months of 2025, compared with 6% to 11% growth in the EU, UK and Japan.
