Tuesday, September 29, 2026
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Follow the Tariff Dollars

Who actually owns the refund, and why the answer isn't complicated.

Before we get into this blog, I want to flag that this is a first for me, a one off editorial departure from the usual news format. I've spent my career on the retailer side of this business, and most of what gets written about tariffs comes from analysts or trade press looking in from the outside. So today I wanted to share some of what I'm actually hearing, from conversations with retailers and from my own experience, about what's going on right now as this refund question plays out.

A lot of the frustration I'm hearing comes down to this: retailers were the ones who had to decide how to handle the tariff cost with the end consumer. There was no guarantee what price the product would actually sell for, so they were the ones taking the risk.

Trade publications and legal opinions have mostly settled on one answer here, that the importer of record has the final say on any refund. That may well be the legally correct outcome, but it sidesteps a more important question, which is who actually bore the risk of pricing that cost to the customer with no guarantee it would sell. That's the question I think deserves more attention, and it's what the rest of this piece is about.

The tariff refund belongs to whoever carried the risk. That's the whole argument, and everything else is just detail.

Here's the reality on the retail side. Retailers placed the order. They paid the invoice with the tariff tacked onto the cost. Then they had to decide how to price that cost into the product for the customer, with no guarantee the market would bear it and no guarantee the piece would even sell at the price they set. That's risk. Real risk, on the price tag, on the showroom floor on the bet that a customer would still pay what it now cost to bring that product in.

So when the refund shows up, it's not a windfall. It's the unwinding of a cost retailers never should have permanently carried. The money flows back to the party that took the risk, the retailer.

There are three camps out there right now.

The first camp did it right. They got the tariff money back and they sent one hundred percent of it to their retail partners, fast, even with a little clawback risk still technically hanging in the air. They didn't wait for perfect certainty. They just did the right thing. These companies will be remembered by their retail partners.

The second camp is the wait-and-see crowd. They say the right words. "We'll take care of you when the dust settles." Maybe they will. But they're sitting on money that isn't theirs while they wait for a level of certainty that may never fully arrive.

The third camp is the one that's most concerning. The 'beat around the bush' group. Ask them a direct question and you get a non-answer. No timeline, no commitment, no straight talk. That tells a retailer exactly one thing, expect nothing.

Here's the honest nuance, though. Some manufacturers in that third camp are genuinely hurting. That tariff money might be the difference between making payroll and not. That's real, not something to dismiss. But the answer to being in trouble isn't to go quiet. The answer is a phone call. "Here's our situation, here's our plan, here's what we can do and when." Reputable retailers will work with honesty all day long. What they won't forgive is being played.

It's worth getting ahead of the argument coming back up the chain, because it's a fair one to raise. Some manufacturers look at retailers and think, wait a minute, the retailer already marked the price up to cover that tariff. The customer paid it. So why does the retailer get the refund? Are they going to hand it back to their customer?

Good question. Here's the answer.

No, the money doesn't go back to the consumer, and here's why. The customer bought a finished product at an agreed price and received exactly what they paid for. Retailers set that price based on the full landed cost and the risk they carried at the moment of the sale. That's honest pricing. That's not an overcharge waiting to be returned. Nobody refunds a customer because the cost of doing business went down after the sale closed. Just like they don't charge a customer more after the product is delivered and they realized the container invoice ended up being more than the retailer expected. The refund settles at the level where the risk actually lived, and that level is the retailer.

So follow the dollar. Trace it back to who took the risk on it. That's your answer every time.

Let me widen this out, because the refund itself might not be the most important part of this conversation.

Retailers are keeping score and they talk to each other. Who was transparent? Who stalled? Who went dark? And that ledger doesn't get erased when this cycle ends. When it's time to set open-to-buy, when it's time to add a group or cut one, that memory is sitting right there in the room. This refund is a loyalty test, and a lot of manufacturers don't realize they're taking it.

How a manufacturer behaves right now is teaching every one of their retail partners exactly what to expect in the future. They're not just settling a refund. They're painting a picture of how future relations will go.

So here's where it lands.

The refund belongs to whoever carried the risk. On this cost, in this cycle, that's the retailer. That's not greed and it's not a technicality. It's just the dollar going back to where the risk lived.

To the manufacturers doing it right: thank you. You've earned a partner for the next decade.

To the ones stalling, understand the trade you're making. You're winning a quarter and risking losing a relationship. And in this industry, the relationship was always worth more than the quarter.

Be transparent. Be timely. Follow the dollar. It's not complicated. It just takes the nerve to do the right thing before you're forced to.



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