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ARTICLE · 07 APRIL 2026

Trade Alert: IEEPA Refund Process Update

On March 27, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued an order in Atmus Filtration Inc. v. United States...

United StatesInternational Law

On March 27, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued an order in Atmus Filtration Inc. v. United States, updating his previous order of March 20, 2026, regarding refunds of duties paid under the International Emergency Economic Powers Act (IEEPA).

The March 27, 2026 order broadens the scope to include finally liquidated entries, encompassing those entries that have completed both the 314-day liquidation cycle as well as the 180-day protest period during which importers can challenge the final assessment of duties imposed by U.S. Customs and Border Protection (CBP) by the protest procedure (19 U.S.C. §1514). Under this new order, the implication is that importers will not be required to file protests for entries that are beyond the date of finality in order to recover the IEEPA duties ("Any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties."). In the March 27, 2026 order, the

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