On March 4th, 2026, the US Court of International Trade (CIT) ordered US Customs and Border Protection (CBP) to begin automatically refunding duties collected under the International Emergency Economic Powers Act (IEEPA). The order applies broadly to all importers that paid IEEPA duties.

Under the order, CBP must liquidate unliquidated entries without applying IEEPA duties and reliquidate entries that have already liquidated but are not yet final, issuing refunds of those duties. Importers should review their entries to determine whether they are unliquidated, liquidated but still within the protest period, or fully final, as this status will determine eligibility for refunds.

“Liquidation” refers to the final calculation of duties on an entry and typically occurs around 314 days after entry, although some entries subject to IEEPA duties have liquidated earlier.

Several issues remain unresolved, including the scope of entries where liquidation is considered “not final” (final liquidation is defined as more than 180 days after the date of liquidation {i.e., the protest deadline}) and whether entries that have already become final will be eligible for relief. Importers with entries approaching the 180-day protest deadline may wish to consider filing protests to preserve potential refund rights although based on the order, this may not be necessary because CBP has been instructed to re-liquidate entries are not yet final.

The ruling may not be the final outcome. The US Government is expected to appeal and could seek a stay from the United States Court of Appeals for the Federal Circuit, which could delay implementation of refunds while the appeal is pending. Additional clarity may follow a conference scheduled before the CIT on March 6th, 2026.

RIM encourages all importers to assess their individual circumstances and select the course of action that most appropriately aligns with their organization’s risk tolerance and business objectives.

In addition, as of February 6th, 2026, CBP has stated that refunds will be issued electronically only to importers enrolled in the Automated Commercial Environment (ACE) Secure Data Portal with Automated Clearing House (ACH) refund authorization.

We strongly advise all customers who have not already done so to establish an ACE Portal account and an ACH refund account with CBP.

If you do not already have an ACE portal account, you can use the link below to sign up. The step-by-step directions can be found here.

ACE ACH instructions can be found here.

RIM logistics, ltd. will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative if you have any further questions or need assistance with ACE/ACH.