On March 4, 2026, in Atmus Filtration, Inc. vs. United States, Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued an order, referencing the U.S. Supreme Court’s February 20, 2026 ruling in Learning Resources, Inc. v. Trump declaring International Emergency Economic Powers Act (IEEPA) tariffs unlawful, that: (1) “[a]ll importers of record whose entries were subject to IEEPA duties are entitled to the benefit of the Learning Resources decision”; and (2) “with respect to any and all unliquidated entries that were entered subject to the IEEPA duties, U.S. Customs and Border Protection [CBP] is hereby directed to liquidate those entries without regard to the IEEPA duties. Any liquidated entries for which liquidation is not final shall be reliquidated without regard to IEEPA duties.”
While this order was not issued in the Learning Resources or V.O.S. Selections, Inc. vs. United States test cases heard by the U.S. Supreme Court, it indicates that Judge Eaton, for efficient administration, will be the only CIT judge to hear cases pertaining to the refund of IEEPA duties. Judge Eaton has scheduled a closed conference for March 6, 2026, and reportedly gave the federal government’s counsel until then to prepare initial steps on how CBP can refund IEEPA tariffs to importers of record without requiring importers to file a complaint with the CIT.
For additional background information, see Thompson Hine updates of February 20, 2026 and March 2, 2026.