IEEPA Tariffs
The International Emergency Economic Powers Act (IEEPA) was invoked by the Trump administration beginning in 2025 to impose broad tariffs on virtually all U.S. trading partners. These tariffs were struck down by the Supreme Court on February 20, and more than $175 Billion in importer refunds remain in dispute. While CBP builds a new CAPE refund system in ACE, the Trade waits to see if the DOJ will file an appeal. If such an appeal materializes, it could create issues for importers who did not filed early IEEPA refund lawsuits.
As of February 2026, Customs is exclusively issuing refunds via the ACE ACH Refunds Module. Apply for an ACE account today.
NEWS IN IEEPA REFUNDS
3/24/26: Early Liquidation Risk Across Entry Types
3/20/26: CIT Expands IEEPA Refund Order to Cover Brazil and India Tariffs
3/18/26: Why the Supreme Court's Mandate Is Potentially Important for IEEPA Refund Strategy
3/17/26: SCOTUS Mandate Likely to Issue in the Near Future
3/13/26: CBP Building New CAPE System to Process IEEPA Tariff Refunds at Scale
3/12/26: Section 122 Tariffs Now Under Legal Challenge at the CIT
3/11/26: Five Days of Silence: Will the Administration Appeal the IEEPA Refund Order?
3/10/26: No Refunds Have Been Issued, But Consumer Class Actions Are Already Here
3/6/26: CIT Hearing Update: CBP Says It Needs 45 Days to Process IEEPA Tariff Refunds
3/4/26: CIT Orders Nationwide Removal of IEEPA Duties on Non-Final Entries
3/3/26: When Does an IEEPA Liquidation Become Protestable?
3/2/26: Federal Circuit Orders Immediate Issuance of Mandate in IEEPA Tariff Case
2/28/26: DOJ Moves to Delay IEEPA Tariff Refund Process
2/27/26: Trump on SCOTUS Rehearing
2/26/26: IEEPA Tariffs: Importers Move for Permanent Injunction and Refunds After Supreme Court Win
2/26/26: CAFC Orders U.S. to Respond on Immediate Mandate in IEEPA Tariff Cases
2/24/26: VOS Plaintiffs Move for Mandate in CAFC; Customs Confirms 10% Worldwide Tariffs
2/23/26: Companies File Protective Lawsuits to Preserve IEEPA Tariff Refund Rights
2/23/26: Senate Democrats Introduce Legislation to Force Rapid IEEPA Tariff Refunds
2/21/26: Claiming IEEPA Tariff Refunds
CLIENT ADVISORIES AND WHITE PAPERS
January 14, 2026: Client Alert: Prepare for SCOTUS Decision on IEEPA Tariffs
January 6, 2026: Summary: Early IEEPA Tariff Refund Litigation
January 6, 2026: White Paper: Litigation Strategy to Protect IEEPA Claims
HISTORY OF THE IEEPA TARIFFS
March 3, 2026: CBP/CIT: When does an IEEPA liquidation become a protestable decision under 19 U.S.C. § 1514? See article.
March 2, 2026: CAFC: Federal Circuit orders immediate issuance of mandate in IEEPA tariff case, clearing path for refund litigation at the CIT. See article.
February 28, 2026: DOJ: DOJ moves to delay IEEPA tariff refund process, requesting 90-day stay of mandate and 120-day pause on refund litigation at the CIT. See article.
February 27, 2026: POTUS: President Trump questions whether the Supreme Court could rehear its IEEPA tariff decision, while exploring alternative statutory authorities for tariffs. See article.
February 26, 2026: CIT: Importers in V.O.S. Selections v. Trump file motion for permanent injunction and refund procedures at the Court of International Trade following the Supreme Court's IEEPA ruling. See article.
February 26, 2026: CAFC: Federal Circuit orders U.S. government to respond to importers' motion for immediate issuance of mandate in IEEPA tariff cases. See article.
February 24, 2026: CAFC/CBP: VOS plaintiffs move for mandate in Federal Circuit; Customs confirms 10% worldwide tariffs under new authority. See article.
February 23, 2026: CIT: Companies file protective lawsuits at the Court of International Trade to preserve IEEPA tariff refund rights. See article.
February 23, 2026: Congress: Senate Democrats introduce legislation to force rapid IEEPA tariff refunds. See article.
February 20, 2026: POTUS issues two Executive Orders in response to the SCOTUS decision:
The first EO, titled ENDING CERTAIN TARIFF ACTIONS, cancels the collection of IEEPA tariffs (without impacting refund claims).
The second EO, titled Imposing a Temporary Import Surcharge to Address Fundamental International Payments Problems implements a 10% worldwide tariff (with certain exceptions) using by invoking the temporary provision of section 122 (to be effective February 24).
February 20, 2026: The U.S. Supreme Court Strikes Down President Trump's IEEPA Tariffs.
April 2025: CBP: FAQ on IEEPA Tariffs (Generally, China, Mexico & Canada)
April 11, 2025: CBP: CSMS Message 64724565, Exclusion of Specified Products from Reciprocal Tariffs
April 8, 2025: POTUS: Executive Order 14259, Amending the Reciprocal Tariff Rate for China
April 4, 2025: China MOFCOM: Announcement of 34% Retaliatory Tariffs on U.S. Goods
April 2, 2025: POTUS: Executive Order 14257, Establishing Reciprocal Tariffs
February 13, 2025: POTUS: White House Article, Reciprocal Trade and Tariffs
February 13, 2025: POTUS: White House Fact Sheet on the Fair and Reciprocal Plan on Trade