Dear Customers, Colleagues, and Friends,
On March 4, 2026, the U.S. Court of International Trade (CIT) issued an order directing U.S. Customs and Border Protection (CBP) to refund tariffs previously collected under the International Emergency Economic Powers Act (IEEPA) on certain import entries.
Major Trade Ruling: Court Orders Refund of IEEPA Tariffs on Certain Imports
- The Court ordered CBP to liquidate all unliquidated entries without applying IEEPA tariffs.
- Any entries that have already liquidated but are not yet final must be reliquidated without the IEEPA duties.
- The decision follows earlier court findings that IEEPA does not provide statutory authority to impose tariffs.
As a result, importers whose entries were subject to IEEPA tariffs may be eligible for refunds, depending on the status of their entries.
Important Considerations
This ruling may not be the final outcome, as the U.S. Department of Justice is expected to appeal the decision.
Additional court proceedings are expected in the coming days to address implementation and refund procedures.
CBP has not yet issued operational guidance explaining how refunds or reliquidations will be processed.
What This Means for You
At this time, no immediate action is required from importers. Until CBP releases formal implementation instructions—likely through a CSMS message or additional guidance—the refund process and timeline remain uncertain. That being said, this is certainly a step in the right direction for importers pursuing refunds on tariffs paid under IEEPA.
**** It is EXTREMELY IMPORTANT to review previous Customer Advisories ( 1/13/26 & 2/4/26) linked here to review the updated refund procedure. We strongly suggest immediately registering for an ACE Portal account, if you haven’t already, and following the ACH REFUND AUTHORIZATION procedure.
We will continue to track all detailed guidance and will notify you as further regulatory instructions are released. In the meantime, if you have any questions or would like to discuss potential impacts on your shipments or sourcing strategy, our team at Krenz & Hannan is ready to assist.
Sincerely, Your friends at Krenz and Hannan International