On March 4, 2026, the Court of International Trade (CIT) ordered CBP to liquidate without regard to the International Emergency Economic Powers Act (IEEPA) duties all unliquidated entries that were subject to tariffs imposed under the IEEPA and to reliquidate of such entries for which liquidation isn't final. The order states:

ORDERED that, with respect to any and all unliquidated entries that were entered subject to the IEEPA duties, U.S. Customs and Border Protection is hereby directed to liquidate those entries without regard to the IEEPA duties. Any liquidated entries for which liquidation is not final shall be reliquidated without regard to IEEPA duties.

The decision by Judge Richard Eaton says, "All importers of record whose entries were subject to IEEPA duties are entitled to the benefit of the Learning Resources decision" in light of the Supreme Court's finding that IEEPA doesn't contain any tariff authority and the trade court's unique ability to issue nationwide relief. Judge Eaton also said CIT Chief Judge Mark Barnett indicated Eaton will be the only judge presiding over cases involving IEEPA duty refunds.

For further information about this and other customs matters, contact George Tuttle III at geo@tuttlelaw.com or 415-986-8780.

The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence and may not be considered as such.

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