CBP Sets 45-Day Timeline for IEEPA Tariff Refund Process — CIT Orders Liquidation and Reliquidation of Entries

U.S. Customs and Border Protection has committed to establishing a tariff refund process within 45 days following a Court of International Trade order requiring the agency to liquidate unprocessed entries and reliquidate processed-but-not-finalized entries tied to invalidated IEEPA tariffs. CIT Senior Judge Richard Eaton issued the order on Wednesday, March 5, 2026, with a mandatory progress report from CBP due by March 12.

The order stems from the Supreme Court's February 2026 ruling that invalidated President Trump's use of the 1977 International Emergency Economic Powers Act to impose broad global tariffs. CBP acknowledged it cannot immediately comply with Judge Eaton's directive but provided the 45-day implementation timeline as its target for processing duty recovery claims.

Key Timeline for Compliance Teams:
• CBP progress report due: March 12, 2026
• Refund process target: 45 days from March 7, 2026
• New replacement tariffs effective for: at least 150 days

For trade compliance engineering teams, this ruling creates immediate implications for entry status tracking. The distinction between "unprocessed entries" requiring liquidation and "processed-but-not-finalized entries" requiring reliquidation means systems must accurately flag entry lifecycle states to identify which records qualify for potential duty recovery workflows.

Data Integrity Alert: The IEEPA tariffs have been replaced with new tariffs that will remain in effect for at least 150 days. Rate caching systems must distinguish between the invalidated IEEPA rates (potentially refundable) and current replacement rates (actively applied). HTS code lookups should return accurate effective dates to prevent misclassification of duty liability.

Costco Wholesale, which filed suit against the Trump administration in late November 2025 seeking refunds of IEEPA levies, announced Thursday that it would pass any recovered tariff payments back to customers. CEO Ron Vachris characterized the situation as "extremely fluid" during the company's fiscal Q2 earnings call, noting uncertainty around "what the process will be, what refunds, if any will be received and when this will happen."

The retailer is not alone in pursuing recovery. Revlon Consumer Products and Bumble Bee Foods filed similar suits prior to the Supreme Court ruling, while FedEx initiated legal action after the decision came down. The liquidation order affects all importers who paid duties under the now-invalidated IEEPA authority.

From a technical standpoint, compliance systems need to support several critical functions during this 45-day window: tracking entry numbers against CBP liquidation status, flagging entries that fall within the IEEPA tariff effective date range, calculating potential refund amounts based on the differential between IEEPA rates and applicable baseline rates, and monitoring CBP bulletins for procedural updates on the reliquidation process.

Costco reported $68.24 billion in net sales for fiscal Q2 ended February 15, 2026, a 9.1% year-over-year increase, with net income rising to $2.04 billion. The company noted it has already begun lowering prices on certain textiles, bedding, and cookware SKUs as some tariff rates have decreased.

Trade compliance teams requiring accurate HTS rate data and entry classification support during this transition period can request a free 30-day trial of the TradeFacts.io API at /contact.html.