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 March 20, 2026 order regarding refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”). (For background on the March 20, 2026 order, see Update of March 23, 2026.) The new order broadens the scope to include finallyliquidated entries—those that have completed both the 314-day liquidation cycle and the 180-day protest period during which importers can challenge the final assessment of duties imposed by U.S. Customs and Border Protection (“CBP”).
Judge Eaton’s latest order thus clarifies that all entries subject to IEEPA duties are entitled to refunds. Previously, Judge Eaton’s March 20, 2026 order indicated that only “unliquidated entries” and “liquidated entries for which liquidation is not final” would qualify for refunds.
Although the March 27 order explains that all entries are eligible for refunds, it remains suspended “to the extent that it requires immediate compliance,” meaning refunds will not be provided for now.