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ARTICLE · 26 MARCH 2026

IEEPA Tariff Refund Update

Boies Schiller Flexner LLP
Boies Schiller Flexner LLP
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Boies Schiller Flexner LLP

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As an update to our prior alert on IEEPA tariff refunds, we are reviewing recent developments in Atmus Filtration...

United StatesInternational Law
Peter M. Skinner
Peter M. Skinner
Adam Shaw
Adam Shaw
Andrew Hersey
Andrew Hersey

As an update to our prior alert on IEEPA tariff refunds, we are reviewing recent developments in Atmus Filtration, Inc. v. U.S. Customs and Border Protection, the case in the Court of International Trade that will control administrative refund mechanics going forward.

Key Takeaways:

  • The CIT is prioritizing an automated refund system and has not (yet) instituted processes for administrative or judicial review of CBP's refund calculations.
  • Importers should preserve their rights by filing timely administrative claims while the process is playing out and should pursue protests under 19 U.S.C. § 1514 for reliquidation of entries for which liquidation has become final.
  • The CIT is maintaining tight control and has rejected efforts by the trade bar to apply a multidistrict litigation-style framework with input from multiple importers.

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