Trade Advisory: End of IEEPA Tariff Collection

Executive Summary

On February 20, 2026, the President issued an Executive Order titled “Ending Certain Tariff Actions,” which terminates the collection of additional ad valorem duties imposed under the International Emergency Economic Powers Act (IEEPA). U.S. Customs and Border Protection (CBP), via CSMS #67834313, confirmed that IEEPA duties will no longer be collected on qualifying entries effective February 24, 2026.

Scope of Relief

Effective 12:00 a.m. Eastern Time on February 24, 2026, IEEPA duties will no longer apply to goods entered for consumption or withdrawn from warehouse for consumption. The termination applies to duties imposed under the following Executive Orders, including amendments:

• EO 14193 (Northern Border / Illicit Drugs)
• EO 14194 (Southern Border Measures)
• EO 14195 (PRC Synthetic Opioid Supply Chain)
• EO 14245 (Venezuelan Oil Imports)
• EO 14257 (Reciprocal Trade Deficit Tariffs)
• EO 14323 (Brazil)
• EO 14329 (Russian Federation)

CBP Systems Impact

CBP will update ACE programming so that HTSUS numbers associated with IEEPA tariffs are inactive as of February 24, 2026. Importers should not expect IEEPA duties to be assessed on qualifying entries filed on or after that date.

Important Limitations

This action applies only to duties imposed under IEEPA. Duties imposed under Section 232 and Section 301 authorities remain in effect unless separately modified.

Next Steps for Importers

In a related development, on December 15, 2025, the U.S. Court of International Trade (CIT) ruled that it has the authority to order reliquidation, and refunds of duties collected under IEEPA should the Supreme Court ultimately find those tariffs unlawful. In that decision, the CIT declined to issue a preliminary injunction to halt liquidation of affected entries, reasoning that importers would not suffer irreparable harm because refunds could be provided through court-ordered reliquidation.

The CIT has also emphasized that the government's stipulation regarding reliquidation applies to all current and future similarly situated plaintiffs.

While formal guidance has not yet been issued, importers should take proactive steps to ensure they are positioned to act quickly if refund or post-entry correction procedures are announced.

• Review impacted entries: Identify all entries on which IEEPA duties were assessed, including entry numbers, dates, and amounts paid.
• Ensure document readiness: Confirm that entry packages are complete and readily retrievable, including CBP Forms 7501, commercial invoices, packing lists, payment records, and any relevant broker communications.
• Validate record retention: Verify that supporting documentation is maintained in accordance with 19 CFR Part 163 requirements to support potential claims or Post Summary Corrections (PSCs)."
• Make sure your company is signed up for the ACH refund process, in case refunds are made available

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