Alerts3.5.26
IEEPA Tariff Refunds: CIT Orders Action, Questions Remain
Highlights
- The Court of International Trade (CIT) has ordered U.S. Customs and Border Protection (CBP) to begin automatically refunding International Emergency Economic Powers Act (IEEPA) duties.
- The order applies broadly to all importers that paid IEEPA duties, but companies must confirm whether their entries are unliquidated, liquidated but not final, or fully final.
- Key uncertainty remains around what qualifies as “not final” liquidation and how this will impact refunds for importations made, particularly in early 2025.
- The ruling may not be the last word; the U.S. government is expected to appeal and could seek a stay pending review.
In a previous alert, we reported that the U.S. Supreme Court struck down President Donald Trump’s tariffs imposed under the IEEPA and that the President was considering other alternative tariffs. We followed up with a subsequent alert about the CBP issuing instructions to end the collection of all IEEPA tariffs, and then President Trump issued a proclamation levying an across-the-board additional tariff of 10% under Section 122 of the Trade Act of 1974.
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