March 6, 2026
On March 4, 2026, the U.S. Court of International Trade (CIT) ordered U.S. Customs and Border Protection (CBP) to remove tariffs imposed under the International Emergency Economic Powers Act (IEEPA), following a U.S. Supreme Court decision holding that IEEPA does not authorize the imposition of tariffs.
The Court directed CBP to liquidate all unliquidated entries without IEEPA duties and to reliquidate entries that have been liquidated but are not yet final, again without applying IEEPA tariffs. The Court emphasized that this relief is intended to apply uniformly nationwide and is not limited to the importer that brought the case.
IEEPA tariffs were applied broadly over several years and affected a wide range of products and industries. CBP has reported that tens of millions of entries and a significant amount of duties are implicated. As a result, the Court’s orders represent a major potential duty relief development for importers.
On March 6, 2026, CBP acknowledged its obligation to comply with the Court’s orders but has advised that implementation will take time. According to CBP, existing systems are not designed to immediately process refunds or reliquidations at this scale, particularly where multiple types of duties were reported on the same entry. CBP is developing new automated functionality within its systems to support the refund process and has indicated that additional guidance will be issued as implementation moves forward.
Importers should be aware that refunds will not be immediate and are expected to be processed in stages. Electronic refunds are now mandatory, and importers should ensure they are properly enrolled to receive payments electronically. Importers may also wish to review entries impacted by IEEPA tariffs, confirm liquidation status, and coordinate with customs brokers and advisors as CBP guidance evolves.
We will continue to monitor developments and provide updates as CBP implements the Court’s orders.
Need support navigating this development?
Our trade and customs specialists are actively monitoring CBP guidance and can assist with entry reviews, refund readiness, and coordination with brokers as implementation unfolds. Reach out to our Tariff Response Unit today.
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