On March 4th, Judge Richard K. Eaton from the U.S. Court of International Trade (CIT) issued an order directing U.S. Customs and Border Protection (CBP) to refund International Emergency Economic Powers Act (IEEPA) tariffs to all importers of record. This follows the Supreme Court’s earlier ruling in Learning Resources, Inc. v. Trump that IEEPA duties were unlawful.
CBP is now directed to take the following steps:
- Liquidate all unliquidated entries without IEEPA duties. Any entry that has not yet been finalized (“liquidated”) must now be closed without IEEPA tariffs.
- Reliquidate eligible liquidated entries without IEEPA duties. Entries that were already finalized but are not yet past the 180-day protest deadline must be reopened and refunded.
This order covers all importers of record with entries subject to IEEPA duties. Importantly, importers do not need to have filed an individual lawsuit to benefit from this order. The CIT has nationwide jurisdiction over customs matters. Judge Eaton (at left) is the sole judge assigned to IEEPA duty refund cases, ensuring uniform application of this ruling.
The ACMA and our lobbying and legal advisers are available to ACMA members for any questions you may have.

