CIT Orders Refunds For Finally Liquidated IEEPA Entries

On July 15, 2026, U.S. Court of International Trade (CIT) Judge Richard K. Eaton issued an update in the International Emergency Economic Powers Act (IEEPA) refund litigation explaining that the Court will begin issuing refund orders for individual plaintiffs in the IEEPA tariff refund litigation. 

The orders are being issued in individual cases because it is the Government’s position that a court order directing the reliquidation of entries, whose liquidation has become final, would be necessary to provide the Government with the authority to reliquidate these finally liquidated entries and provide complete relief to Plaintiffs. In other words, the DOJ will not voluntarily refund duties on finally liquidated entries without a court order compelling it to do so. The CAPE system — the Government’s voluntary refund system — has not accepted for processing any finally liquidated entries, nor any entries liquidated for more than 80 days. As a result, the Government has represented that it will refund estimated IEEPA duty deposits only to Plaintiffs that challenge the duties in court, meaning that relief for finally liquidated entries is available only to importers who have filed suit. These orders will cover all remaining liquidated IEEPA tariffs paid by importers. Non-plaintiffs will be unable to otherwise recover these tariff payments.

Next steps for non-Plaintiffs

In order to be covered by an individual refund order covering all IEEPA tariff payments, importers must file a complaint with the Court of International Trade. The essential elements required for a complaint is the name of the legal entity importing into the U.S., the importer ID numbers associated with that legal entity, and confirmation that IEEPA tariffs were paid by the importer.