The Court of International Trade has amended a prior order concerning tariffs implemented under the International Emergency Economic Powers Act (IEEPA), expanding the scope of relief for importers.
Under the revised order, all affected entries are now included—covering unliquidated entries, liquidated but non-final entries, as well as entries that have already been finally liquidated. U.S. Customs and Border Protection (CBP) has been instructed to reliquidate these entries without applying the IEEPA-based tariffs, following their invalidation.
This development broadens the potential for importers to recover duties previously paid under the affected tariff measures. However, implementation remains dependent on CBP’s operational readiness. The agency is currently developing a structured refund mechanism, with progress underway on a multi-step processing system to manage claims and disbursements. At present, the system development is estimated to be between 45% and 80% complete across its key components.
The timeline for refunds will depend on further procedural updates from CBP and the court, as systems and processes are finalized. For businesses engaged in international trade, this development may have implications for cost recovery, compliance reviews, and financial planning within supply chain operations.