On February 20, 2026, the Supreme Court ruled that IEEPA does not confer any tariff-setting authority and effectively struck down all IEEPA duties.
The White House has issued an Executive Order that officially ends all IEEPA duties.
Subsequently, CBP issued CSMS # 67834313 – Ending Collection of International Emergency Economic Powers Act Duties declaring IEEPA no longer in effect as of February 24, 2026 at 12:00 am.
The Court of International Trade (CIT) is tasked with deciding on the process to issue the IEEPA duty refunds. This will likely take several months.
Until then, we will not know what the process of obtaining refunds will be, nor what will be required from importers to secure their refunds.
Many trade attorneys urge importers to prepare for all eventualities and take every possible action to protect their potential refunds including filing protective protests on entries that are nearing the protest deadline.
It is unclear whether protests will be effective in protecting potential IEEPA refunds, but filing a protest may protect your refunds, if the CIT decides not to issue refunds on liquidated entries.
Once an entry finally liquidates (i.e,. generally 180 days beyond initial liquidation and is beyond the protest deadline, or approximately 480 days from date of entry), the only avenue for protecting your liquidated entry will be to file a lawsuit in the CIT under 28 U.S.C. 1581(i) jurisdiction.
If your company decides to proceed with a protective protest, Deringer can assist you with this service, for a fee. Please contact consulting@anderinger.com for further assistance.
We recommend checking with a trade attorney to determine your company’s best course of action to protect potential refunds.
Please note that Post Summary Correction (PSC) filings currently cannot be submitted for unliquidated entries that remove IEEPA tariffs.
We continue to advise importers to monitor transactions and liquidation status where IEEPA duties have been paid, as well as the amount of IEEPA duties paid.
If you don’t have an ACE account, we recommend that you establish an ACE account immediately.
As of February 6th, 2026, CBP now issues any and all types of refunds electronically via ACH.
Please note that CBP will reject any refunds if the importer or the importer’s designated Customs Broker is not able to accept electronic refunds through ACH.
2026 Tariff Turbulence: What Importers Need to Know Following the End of IEEPA
Many uncertainties remain following the Supreme Court’s February 2026 ruling that brought the IEEPA tariffs to an immediate end, followed by the introduction of new Section 122 tariffs.
Join us for a critical, real time briefing where Michael Roll, partner at Roll & Harris LLP and a leading international trade attorney, will break down what we know now, what’s still uncertain, and how importers can prepare for this rapid regulatory transition.
Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.