March 5, 2026 in Customer Advisory
Customer Advisory: U.S. Compliance Update – IEEPA Tariff Processing and Refund Developments
Recent developments in U.S. trade compliance may impact importers that previously paid duties imposed under the International Emergency Economic Powers Act (IEEPA). A ruling by the U.S. Court of International Trade (CIT) has directed U.S. Customs and Border Protection (CBP) to process certain unliquidated entries without the assessment of invalidated IEEPA tariffs, following the U.S. Supreme Court’s earlier decision.
While this development represents a meaningful procedural step, refunds are not immediate, and additional administrative actions are still required before funds are returned to eligible importers.
What Has Changed
A judge of the U.S. Court of International Trade, Richard Eaton, has ordered the U.S. government to finalize import entry paperwork without charging IEEPA based tariffs on unliquidated entries affected by the Supreme Court’s ruling. The judge has also been designated to oversee all related refund cases, reducing the risk of inconsistent judicial outcomes. This ruling applies to unliquidated entries only and does not, by itself, trigger automatic refunds for duties already paid.
What This Means for Importers
- No immediate refunds: Importers should not expect instant reimbursement. The ruling advances the process but does not complete it.
- Refunds apply to importers of record, not consumers or downstream buyers.
- Millions of entries may be affected, and CBP is expected to require additional time and formal guidance to manage processing at scale.
- Further instructions from CBP and the Court of International Trade are anticipated before refund mechanisms are fully operational.
Recommended Customer Actions
Importers may wish to consider the following steps:
- Identify unliquidated entries that may be subject to IEEPA tariff removal
- Ensure entry documentation and payment records are complete and accessible
- Monitor CBP and court guidance regarding refund filing procedures
- Consult with customs brokers or legal advisors before initiating protests or Post Summary Corrections, as premature filings may increase cost without accelerating refunds
Our Support
APL Logistics continues to monitor developments related to IEEPA tariff processing and refund procedures. While we do not provide legal or tax advice, our teams can assist customers by sharing updates as CBP and the Court of International Trade issue further guidance.
Sincerely,
APL Logistics
Sources
- Kintetsu World Express: Customer Advisory 2026_23 – U.S. Compliance Update (U.S. Court of International Trade orders unliquidated entries processed without IEEPA tariffs), March 4, 2026
Disclaimer: This advisory does not constitute legal advice and is issued for general information purposes only. APL Logistics accepts no responsibility for any information contained within this advisory and refutes and excludes any liability in respect of the contents or for action taken based on such information.
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About APL Logistics
APL Logistics is a leading global supply chain logistics provider focused on order management. With over four decades of experience, we offer innovative, end-to-end supply chain solutions across various industries. With a strategic balance of our world-class account management teams, proprietary digital solutions, and an extensive network, APL Logistics’ Order Management will enable your business to stand out, adapt faster, and execute more efficiently than your competitors.
The APL Logistics group of companies has a global network covering all major markets and is backed by a multinational workforce. APL Logistics Ltd is a member of the Kintetsu World Express group, a global logistics services provider. For more information, visit www.apllogistics.com, email us at global_marketing@apllogistics.com, and connect with us on LinkedIn, Instagram, and YouTube.