CIT expands refund order to finally liquidated entries

On March 27, Judge Richard Eaton of the U.S. Court of International Trade (CIT) expanded his prior order directing U.S. Customs and Border Protection (CBP) to refund IEEPA tariffs. While the original order applied only to non–finally liquidated entries, the court has now clarified that it also applies to finally liquidated entries.

Specifically, the order states that “any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties.” However, the court continues to suspend the order to the extent it would require immediate compliance, meaning CBP is not yet obligated to take immediate action.

Although Judge Eaton’s ruling provides insight into a potential framework for the refund process, further challenges, changes, or delays remain possible. Refunds should not be expected to occur automatically.

Recommended Action:
Importers are advised to consult with counsel to evaluate whether proactive steps, such as filing protests with CBP and/or pursuing claims before the Court of International Trade, may be appropriate to preserve potential refund rights.

We will continue to monitor developments and provide updates as additional guidance becomes available. For questions regarding how this decision may affect your imports, please contact your Deringer representative.

Deringer Customers: Get Started with Electronic Refunds Here

To let us know how we may best assist you, please complete our client form for IEEPA protests and electronic refunds. Go to the Form

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.