The U.S. Court of International Trade amended its IEEPA tariff refund order on March 20, 2026, expanding the scope while continuing to delay implementation.
The Court clarified that the directive now covers all duties imposed under IEEPA, including those applied to imports from Brazil and India. This update expands the population of affected entries but does not change the current execution timeline.
WHAT REMAINS UNCHANGED FOR IMPORTERS?
The order does not address how to process entries that have already reached final liquidation. Importers must rely on statutory protest mechanisms under 19 U.S.C. § 1514 to pursue recovery where applicable.
CBP continues to develop its process to issue refunds of IEEPA duties with interest, with progress tied to ongoing system development.
WHAT HAPPENS NEXT IN THE IEEPA REFUND PROCESS?
The Court requires CBP to submit a status report by March 31, 2026, and will hold additional proceedings the same day.
The expanded scope increases potential eligibility, but refund timing and execution remain on hold.
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