CIT Orders CBP to Liquidate IEEPA Entries

On March 4, 2026, the Court of International Trade (CIT) ordered U.S. Customs and Border Protection (CBP) to liquidate all unliquidated entries without applying the IEEPA duties. Any liquidated entries for which liquidation is not final shall be reliquidated without the IEEPA duties.

What does this mean for Importers?

• Refunds are still uncertain, though the signs are positive. We need to await more information on whether the order will be appealed and for more details.
• This order applies to all importers.
• If there are no changes to the order, CBP should issue refunds to importers who paid IEEPA tariffs on entries that have not liquidated. Liquidation typically occurs within 314 days of entry.
• The order also includes a provision for reliquidating entries that have already liquidated, but have not been finalized. This is the same 180-day period of time during which an importer can file a protest (correction) to an entry that has already liquidated.

What’s Next?

The court is holding a closed conference on Friday, March 6, 2026, to discuss next steps. Following the meeting, we expect more details to be shared with the public. Also, it’s anticipated the government will appeal the order.

What Actions Should Importers Take?

Establish an Importer ACE Portal Account

• Contact your NNR representative to add a Point of Contact to your 5106 Importer Record on file with U.S. Customs.
• Apply for an Importer ACE Portal Account
• Companies without an ACE Portal Account can use the automated application.

Authorize ACH Refunds

• For more information on how to authorize ACH Refunds see: ACE Portal – ACH Bank Information for Electronic Refunds

Download ACE Reports

• ACE Report ES-003 contains Entry Summary Data to help you determine the amount of IEEPA duties paid.
• ACE Reports for liquidation can provide liquidation tracking information.
• Guidance on how to navigate ACE Reports is available here: ACE Training and Reference Guides | U.S. Customs and Border Protection

Questions?

We’re Here to Help – Reach Out to Your NNR Representative