The U.S. Court of International Trade has ordered the government to liquidate all unliquidated entries that were subject to IEEPA duties without collecting those duties in one of the IEEPA cases pending before the Court. The Court has further ordered that any liquidated entries “for which liquidation is not final” be reliquidated without regard to IEEPA duties.
This order applies nationwide to all covered entries, whether or not the importer is a party to the pending lawsuits. The phrase “liquidated entries for which liquidation is not final” is not yet clearly defined, but the directive for unliquidated entries is straightforward: CBP is to complete liquidation without IEEPA duties, which should result in refunds with interest where those duties were previously paid.
The government may seek to delay implementation — for example, by appealing the court order or creating additional administrative processes — but this development is a significant step toward securing IEEPA duty refunds.
For our previous client alerts concerning IEEPA refunds, please see our February 21 and March 2, 2026 alerts.