What importers need to know about CBP refund timing, court actions, and next steps
We wanted to provide a quick update on the ongoing court case related to IEEPA tariffs and U.S. Customs (CBP) refund processing, based on the government’s May 29th filing. You can review the full filing here: c866ddd9-88c4-4f84-a548-04e48aa0b288.pdf
Key Takeaways
1. Tariff Refunds Are Underway (Partially)
- CBP has already begun refunding ~$85 billion in tariffs on entries that are still unliquidated (not final).
- Additional refunds are expected in the coming weeks as more claims are filed for unliquidated entries or those w/in 80 days of having been liquidated by CBP.
2. Final (Liquidated) Entries
Entries without specific court cases filed in the Court of International Trade (CIT):
- Depending on the outcome of this recent action, filing in the CIT may be the only way to secure refunds for finally liquidated entries, but this is not yet decided.
3. Timing & System Limitations
- CBP has confirmed that full, immediate compliance is not possible for finally liquidated entries.
- Refunds will be processed through a phased rollout of system enhancements.
What This Means for You
- Refund timing depends on:
- Whether entries are finally liquidated or unliquidated
- Whether an individual court case has been filed
- CBP’s ongoing system updates
- Additional delays and legal developments are likely, especially for finally liquidated entries without litigation.
We will continue to monitor this closely and keep you updated. If you have questions about how this impacts your entries, please reach out to your Deringer representative or consult your Customs Attorney.