When the Supreme Court struck down the Trump administration’s global tariffs in February, there was understandable skepticism in the industry that refunds would ever be paid out. However, despite stories of technical difficulties with the portal that U.S. Customs and Border Protection (CPB) launched last month, it appears that the refund process is moving along at a surprisingly brisk pace. In a message sent to shippers on May 4, CPB estimated that the first refunds would be hitting importers’ bank accounts today.

But just having a business impacted by the tariffs doesn’t make you eligible for a direct refund from CPB. You’re only able to collect the funds if you were the importer of record for a shipment. That means that if you used a broker or any other third-party business to bring goods to the U.S., you’re not a candidate. Even within the category of importers that are able to apply, there’s additional red tape to qualify: The first phase of the process is limited to shipments that were “liquidated,” or finalized, within the past 80 days, as well as some unliquidated shipments during that same time period.

“Unless you’re a super sophisticated importer or broker, you’re probably part of the group of the total entries that are [otherwise] eligible for a refund that weren’t included in this first phase of the Consolidated Administration and Processing of Entries [CAPE] rollout,” says Josh Rutstein, an attorney at real estate and corporate law firm Zandi Rutstein. “It’s a microscopic portion of importers that are eligible for refunds at this point. It’s a very restrictive program.” The system was built to process the easiest claims first as the CPB figures out a way to address more complicated ones; while further phases of CAPE are expected, CPB hasn’t provided a timeline for expanding the program.

Roughly $166 billion in U.S. tariff collections are subject to potential refunds. For those companies that will have ACH payments deposited to their bank accounts as soon as today, there is a question of what they’ll do with them. Some, like Costco and Home Depot, have made vague promises about using the money to add value to their customers. More specific pledges have come from mega-shippers UPS, FedEx and DHL, all of which have committed to passing their refunds on to customers who were affected by the levies. “As soon as we get that money, we’re going to remit it right back to ⁠our ​customers,” UPS CEO Carol Tomé said in a post-earnings investor call, during which she also stated that the company had collected about $5 billion worth of tariffs from its customers.

The question of what to do with the refund is more of a moral issue than a legal one, says Seth Kaplowitz, managing partner of legal and business strategy firm Kaplowitz Group. For interior designers who aren’t importers but regularly work with brokers or third-party agencies on imports, there is a possibility that those entities could return the cost of paid tariffs to them. Then the question of what to do with the money trickles down to the designer. “A lot of the conversation around this that I’ve seen is, ‘If I get a refund, what am I supposed to do with it?’ That really has to do with how you billed for the tariffs in the first place,” says Kaplowitz. “If it was a separate line item, that’s a little more clear than if you added it to an overall markup. But, broadly speaking, if you passed along the cost of the tariff to your client and they paid it, if you get that money back, yes, you should be returning it to them.”

The system at present is better suited to helping major companies—like the aforementioned shipping giants or, say, Target—to get refunds, as they have entire teams of accountants and lawyers at the ready to navigate the system. For a small company bringing over an occasional shipping container, the process is not as simple to navigate, since even the data entry involved can subtract otherwise billable hours from a business owner’s day. “It’s easier for [large companies] to wrap their arms around the entries that are included in the Phase 1 rollout and say, ‘OK, we’re in compliance with the Court of International Trade’s order. We can start validating, and prove the system works, and get everyone off our backs,’” says Rutstein.

That said, Rutstein emphasizes that even if you run a small business but are definitely the importer of record on eligible imports, you should do whatever you can to get your refund. “Even if it’s a small dollar amount that you might have been exposed to, you should definitely be thinking through how you can get in line. Make sure that your customs entries are audited and correct, make sure that you can get access to or refresh your access to the CPB’s portal, and then take the steps necessary to submit for the CAPE declarations,” he says. “Whether you’re a designer or you’re selling some textiles or bringing in some things, go ahead and have those conversations. Do not just say, ‘Well, you know, I don’t fit. I’m not a FedEx; I’m not a Costco.’ The law is clear: If you paid those tariffs directly, you’re owed a refund.”