On March 4, 2026, the U.S. Court of International Trade (CIT) issued an order in Atmus Filtration, Inc. v. United States (gov.uscourts.cit.19346.21.0.pdf) directing U.S. Customs and Border Protection (CBP) to liquidate or reliquidate entries subject to IEEPA duties without regard to those duties.
The order follows the recent U.S. Supreme Court decision in Learning Resources, Inc. v. Trump, which found the IEEPA tariffs unlawful. According to the CIT, importers whose entries were subject to IEEPA duties are entitled to the benefit of that decision.
Under the CIT’s order:
- Unliquidated entries subject to IEEPA duties must be liquidated without those duties.
- Liquidated entries that are not yet final must be reliquidated without IEEPA duties.
The court’s language indicates the order may apply broadly to importers whose entries were subject to the IEEPA tariffs, not only the parties in the case.
This development is expected to be appealed, and additional guidance from CBP is anticipated regarding how refunds will be administered.
What Importers Should Do
At this stage, importers should continue monitoring developments and ensure they are tracking liquidation status and protest deadlines for potentially impacted entries.
Importers should also ensure they have an ACE account with ACH refunds enabled in ACE.
As your Customs Broker, we can assist with:
- Running ACE reports to identify entries where IEEPA duties were paid
- Monitoring liquidation status
- Preparing and filing protests where appropriate
- Assisting with ACE account and ACH refund set up
Some importers may have circumstances that add complexity. In those situations, consultation with qualified trade counsel may be appropriate to determine the best course of action. We are happy to coordinate with your legal advisors where needed.
For more information on how we can assist your company in identifying impacted entries or preparing for potential refunds, please contact compliance@shiptlr.com.
We will continue monitoring developments and will provide updates as additional information becomes available.
