Trade Alert: IEEPA Tariffs Refund – Not So Fast!

Please be advised that the order is not likely to take effect immediately. It is expected that this order will be appealed by the government, and that further proceedings will be discussed.

A non-public conference is scheduled for 10 a.m. on Friday, March 6, to discuss next steps and the potential development of a refund process.

Please read our prior e-blast, which includes our recommendation to establish an ACE Portal account and enroll in electronic refunds. This is a mandatory requirement from CBP in order to receive your refunds. 

To apply for ACE Portal and enroll to CBP ACH refund program:

https://ace-accounts.cbp.gov/s/importer-form

March 4, 2026

The U.S. Court of International Trade (CIT) instructed U.S. Customs and Border Protection (CBP)  to liquidate all unliquidated entries subject to tariffs imposed under the International Emergency Economic Powers Act (IEEPA), disregarding those duties entirely.  The Court also ordered that any entries already liquidated but not yet final must be reliquidated without applying IEEPA duties.

From the Court’s Order:

“ORDERED that, with respect to any and all unliquidated entries that were entered subject
to the IEEPA duties, U.S. Customs and Border Protection is hereby directed to liquidate those entries without regard to the IEEPA duties. Any liquidated entries for which liquidation is not final
shall be reliquidated without regard to IEEPA duties.”

The Court’s Order can be found here.

Flegenheimer International highly recommends that you (1) Enroll in CBP’s ACE Refund portal, if you are not yet enrolled and, (2) Pull a report of all entries that are liquidated and unliquidated in ACE Portal.

We advise that you consult with trade attorneys for any entries liquidated prior to September 5, 2026 as filing a court case in the CIT might be the only reliable route to secure a refund. 

We will continue to monitor updates and keep you all posted. 

To run an Entry Summary Report in ACE Portal :

https://www.cbp.gov/trade/automated/training-and-reference-guides

Thank you,

Flegenheimer International