On March 27, 2026, U.S. CIT Judge Eaton issued an amended order broadening the scope of the IEEPA tariff refund. The Court’s original order applied only to unliquidated and non-finally liquidated entries. However, the March 27 amendment now explicitly includes finally liquidated entries, directing U.S. CBP to reliquidate such entries without regard to IEEPA duties.
As amended, the order provides that all unliquidated entries subject to IEEPA duties are to be liquidated without those duties, and that liquidated entries, whether final or not, are to be reliquidated without regard to IEEPA duties. This represents a significant expansion of the original order, as it opens the possibility of refunds for entries that were previously considered final and no longer eligible for correction.
The Court continues to suspend the order to the extent that it requires immediate compliance, meaning CBP is not yet obligated to act on these directives until further notice.
We will continue to monitor developments and provide updates as they become available.