Guidance and Action Plan Regarding IEEPA Tariff Refunds (3/30/26)

March 30, 2026

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New update from Judge Eaton:

TL;DR: the Court has now made clear that all IEEPA-affected entries, unliquidated, liquidated but not final, and liquidated and final are within the scope of the relief, with timing dependent on further court and CBP action. The next update from CBP on CAPE development is expected at the end of the month or in the middle of next week.

As before, the Court reiterated that de minimis issues under 19 U.S.C. § 1321 are not addressed and remain before the Court in separate litigation.

Importantly, the Court continues to suspend the order to the extent it requires immediate compliance, meaning CBP is not yet required to implement liquidation or reliquidation while the stay remains in place.

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