On July 15, 2026, the U.S. Court of International Trade (CIT) issued an order to refund all IEEPA tariffs for entries that have been liquidated for more than 180 days. This order applies only to those importers with pending IEEPA cases before the CIT, which number approximately 3,700 cases.
Which Liquidated Entries Are Eligible for Refund Relief?
“Finally liquidated entries” for more than 90 days are subject to this refund relief, however entries which were liquidated 80 days prior are also eligible because the CAPE system allows for an 80-day cutoff and an additional 10-day processing period.
Refunds Remain Limited to Importers with Pending CIT Cases
For those who filed individual CIT actions, this order is an affirmative directive by the Court directing U.S. Customs and Border Protection (CBP) to process refunds of liquidated entries which otherwise might be beyond CBP’s ordinary reliquidation authority.
At this point, refund of liquidated entries for those who are not before the CIT remains undecided. Separate appellate and class proceedings may determine what happens to those with liquidated entries who are not before the court.
Importers With Liquidated IEEPA Entries Should Consider Next Steps
Currently, CBP’s stance is “no lawsuit, no refund” for finally liquidated entries. There is generally a two-year window from the date of the denied protest or liquidation to file a summons and complaint in the CIT. If your company has substantial liquidated entries with IEEPA duties, you should consider filing suit against CBP in the CIT to obtain refunds of those duties.
If you have questions about the IEEPA tariffs, feel free to reach out to our international team or connect with Dino Vasquez. Our team is here to help.
This article is provided for informational purposes only—it does not constitute legal advice and does not create an attorney-client relationship between the firm and the reader. Readers should consult legal counsel before taking action relating to the subject matter of this article.
