On March 4, 2026, the United States Court of International Trade (CIT) issued an order directing U.S. CBP to liquidate all unliquidated entries that were entered subject to IEEPA duties, and to reliquidate entries that have already been liquidated but are not yet final, removing the IEEPA duties and providing refunds where applicable.
The order follows a decision by the Supreme Court of the United States in Learning Resources, Inc. v. Trump, which found that IEEPA does not grant authority to impose tariffs.
The order applies to all importers, regardless of whether they filed suit. However, it does not currently apply to entries that have been finally liquidated.
Judge Richard Eaton stated that the court’s ability to grant nationwide relief and the need to avoid thousands of individual refund cases supported the issuance of the order. He also stated that he will be assigned to all pending IEEPA duty refund cases, including matters related to the implementation of refunds.
During the hearing, attorneys from the U.S. Department of Justice requested a stay of the order pending appeal, but the request was denied from the bench. The court has scheduled a non-public conference for March 6 to discuss the logistics of implementing refunds, the potential treatment of finally liquidated entries, and CBP’s proposed process for issuing refunds.
The government is expected to appeal the order to the United States Court of Appeals for the Federal Circuit, which previously vacated an earlier CIT order in V.O.S. Selections v. Trump.
While the order directs CBP to begin addressing refunds for unliquidated and non-final entries, it may not represent the final resolution of IEEPA tariff refunds. Importers are therefore advised to continue monitoring developments, consider filing protests within the 180-day statutory period for liquidated entries, and evaluate whether filing suit at the CIT may be necessary, particularly for entries that have already been finally liquidated.