On May 16, 2025, Customs and Border Protection (CBP) issued a Notice to implement President Donald Trump’s earlier Executive Order (EO) 14289 that eliminated the “stacking” (or accumulation) of certain overlapping tariffs. These overlapping tariffs included the IEEPA tariffs on Canada and Mexico, the Section 232 automobile and automotive part tariffs, and the Section 232 steel and aluminum tariffs. For details, See Thompson Hine Update of April 30, 2025.
Importantly, the CBP Notice states that beginning on May 16, 2205, importers may request a refund of tariffs that were previously stacked in contradiction to this order. Importers may file a post summary correction (PSC) for unliquidated entries or file a protest under 19 U.S.C. 1514 for entries that have been liquidated but for which the protest period has not yet expired.