The IEEPA Tariffs Are Gone: Now What?

On February 20, 2026, the Supreme Court issued a landmark decision in Learning Resources, Inc. v. Trump (No. 24-1287) and Trump v. V.O.S. Selections, Inc. (No. 25-250), holding 6-3 that the International Emergency Economic Powers Act (IEEPA) does not grant the President authority to impose tariffs. The same day, President Trump issued an Executive Order rescinding IEEPA tariffs and directing agency heads to "terminate the collection" of those tariffs "as soon as practicable."

While the IEEPA tariffs are being wound down, it is important that businesses keep in mind that other significant tariffs remain in place under different legal authorities, and the President already has announced that he will impose new tariffs to take the place of IEEPA tariffs. Moreover, the refund process for tariffs already paid is uncertain and potentially complex. While all of this gets sorted out, it is important for businesses to review their supply chain and other contracts which were