On March 4, 2026, the United States Court of International Trade (CIT) issued an order in Atmus Filtration, Inc. v. United States directing U.S. Customs and Border Protection (CBP) to liquidate or reliquidate certain import entries without applying duties imposed under the International Emergency Economic Powers Act (IEEPA).
The case arises from duties previously imposed through executive orders invoking IEEPA. The plaintiff, Atmus Filtration, sought injunctive relief and monetary recovery, including refunds of duties paid on affected imports. The CIT’s order follows the recent decision of the Supreme Court of the United States in Learning Resources, Inc. v. Trump, which determined that the tariffs imposed under IEEPA were unlawful.
In implementing that ruling, the CIT directed CBP to liquidate all unliquidated entries subject to the IEEPA duties without those duties, and to reliquidate entries that have been liquidated but are not yet final, effectively enabling refunds for affected importers. The court emphasized its exclusive jurisdiction over international trade disputes and the need for uniform administration of customs duties across the United States.
From a trade compliance perspective, the order is significant because it confirms a procedural pathway for importers to recover tariffs paid under the invalidated IEEPA measures. Refunds may be available through liquidation adjustments, reliquidation, or litigation depending on the status of entries and protest timelines.
Companies that imported goods subject to IEEPA tariffs should review entry records, liquidation status, and applicable protest periods to determine eligibility for refunds. Coordination with customs brokers and legal counsel may be necessary to evaluate whether claims, protests, or litigation actions are required to secure duty recovery.
Please refer to the attached court document (Court No. 26-01259):