Brief update on the CIT ruling related to IEEPA and refunds / liquidation of entries.
In Atmus Filtration, Inc. v. United States (March 4, 2026), the CIT directed U.S. Customs and Border Protection (CBP) to liquidate all unliquidated entries subject to IEEPA duties without regard to those duties, and to reliquidate any non-final liquidations accordingly. This follows the U.S. Supreme Court’s decision in Learning Resources, Inc. v. Trump (Feb. 20, 2026), which held the IEEPA duties unlawful.
What does this mean for importers?
First, this is not a narrow ruling. The Court made clear that importers whose entries were subject to the IEEPA duties are entitled to the benefit of the Supreme Court’s decision. The order applies to:
- All unliquidated entries are subject to IEEPA duties
- Liquidated entries that are not yet final
Second, the Court addressed the Supreme Court’s recent decision limiting “universal injunctions,” distinguishing the CIT’s national and exclusive jurisdiction over trade matters. The message is clear: in the trade context, uniformity matters both statutorily and constitutionally.
This is good news, but how exactly CBP will administer this ruling remains to be seen… to state it simply: CBP should process all entries, excluding IEEPA duty amounts, and refund duties already paid through the liquidation and re-liquidation process. There should be more clarity in additional rulings this Friday, and we will keep you posted.
Logistics Plus suggestion is to stay alert and follow the steps below:
- Watch your liquidation dates from the ACE reports
- Consider an HS compliance audit by Gaia Dynamics tools – as a first step, but a potential deeper audit is needed as CBP might intensify reviews and audit entries before issuing refunds
- Work with Logistics Plus to ensure that all your entries are accompanied by complete back-up and that refunds are processed in whichever mode CIT and CBP decide to administer
If you have questions or need assistance, Logistics Plus is here to support you. Let us know.
