On June 24, 2026, Customs and Border Protection (CBP) issued two Interim Final Rules indefinitely suspending the $800 de minimis duty exemption for all modes of importation of goods into the United States and establish a new informal entry and bonding process for international mail shipments. Public comments on these two interim rules are due

On June 23, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #69035485, confirming that Phase 2 of the process for refunding duties paid by importers of record under the International Emergency Economic Powers Act (“IEEPA”) will be deployed in the Automated Commercial Environment (“ACE”) Portal on June 29, 2026. 

On June 3, 2026, President Donald Trump signed an Executive Order, “Strengthening Customs Enforcement,” (Order) directing the U.S. Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to implement comprehensive reforms targeting importers of record, customs brokers, and international supply chains.

Key Provisions

Importer of Record Requirements. Within 180 days

At a show cause hearing before the U.S. Court of International Trade (“CIT”) on June 9, 2026, U.S. Customs and Border Protection (“CBP”) confirmed that it will roll out Phases 2 and 3 of its process for refunding duties paid by importers under the International Emergency Economic Powers Act (“IEEPA”) later this summer, with Phase

On June 2, 2026, the U.S. Department of Justice (“DOJ”) on behalf of the Trump administration formally appealed at the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) the order of Senior Judge Richard Eaton of the U.S. Court of International Trade (“CIT”) compelling U.S. Customs and Border Protection (“CBP”) to refund importers

In a May 29, 2026 filing, the U.S. Department of Justice (“DOJ”) indicated it planned to appeal a U.S. Court of International Trade (“CIT”) injunction requiring U.S. Customs and Border Protection (“CBP”) to refund duties collected under the International Emergency Economic Powers Act (“IEEPA”).

Background

On March 4, 2026, CIT Senior Judge Richard Eaton

On April 14, 2026, U.S. Court of International Trade Senior Judge Richard Eaton held a closed conference in the new lead case, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al., addressing refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”).  At the conclusion of the conference, the Judge

On April 10, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #68315804, confirming that Phase 1 of the process to refund duties paid by importers under the International Emergency Economic Powers Act (“IEEPA”) will launch on April 20, 2026.  Known as the Consolidated Administration and Processing of Entries (“CAPE”)

On March 17, 2026, Chief Judge Mark Barnett of the U.S. Court of International Trade (“CIT”) issued an order of reassignment transferring cases seeking refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”) to CIT Senior Judge Richard Eaton.  Chief Judge Barnett’s order effectively ratified Judge Eaton’s March 4, 2026 order in

On March 6, 2026, Brandon Lord, a U.S. Customs and Border Protection (CBP) official who, inter alia, leads CBP’s strategic efforts to enforce and protect tariff revenue, submitted a declaration to the U.S. Court of International Trade outlining a proposed process for issuing refunds for importers who have paid tariffs under the International Emergency Economic