CIT Orders CBP to Liquidate Entries Without IEEPA Tariffs — How to Track 300-Day Windows and Refund Status in Your Systems

CIT Senior Judge Richard Eaton ordered CBP on Wednesday to liquidate and reliquidate import entries "without regard" to IEEPA tariffs struck down by the Supreme Court last month — a ruling that directly impacts how trade compliance systems must now track duty amounts, liquidation status, and refund eligibility across potentially millions of entry records.

For engineering teams maintaining tariff calculation engines, this order introduces a significant data state problem: entries processed under IEEPA rates are now subject to recalculation, but the timing and mechanics depend entirely on where each entry sits in the liquidation lifecycle. CBP's standard liquidation window runs approximately 300 days from entry date, during which importers can submit revisions to entry data. Systems tracking duty liability must now flag entries within this window as candidates for IEEPA duty removal upon liquidation.

Entry State Logic Update: For unliquidated entries where IEEPA tariffs were estimated but not yet paid, CBP will simply remove the IEEPA charge at liquidation. For entries where IEEPA duties were already collected, refunds will be issued — but only after CBP review. Your duty calculation cache should distinguish between these two states when surfacing liability estimates to users.

The refund mechanism introduces additional integration requirements. Importers must register for ACH electronic refunds through CBP's Automated Commercial Environment (ACE) to receive faster processing. If your platform manages importer profiles or compliance workflows, surfacing ACE/ACH registration status is now operationally critical. According to trade attorney James Kim of ArentFox Schiff, "importers set up for ACH will receive their money faster and with less friction."

Federal Appeal Expected: Trade attorneys indicate there is a near-certain likelihood the federal government will appeal the CIT ruling to the Federal Circuit. This could delay CBP action on refunds indefinitely. Systems should treat IEEPA refund eligibility as provisional until the Federal Circuit issues its ruling. Do not automatically zero out IEEPA duty amounts in finalized entry records.

The most complex scenario involves entries that have already liquidated with IEEPA duties assessed and paid. These will require either protests filed within applicable deadlines or resolution through whatever refund mechanism CBP ultimately establishes. According to Pete Mento of Baker Tilly, "The real complexity — and where the real money sits — is with entries that already liquidated with IEEPA duties." Engineering teams should implement protest deadline monitoring for these entries, as missing the window forecloses the primary administrative remedy.

CBP has confirmed that refunds will not be automatic or instantaneous — the agency plans to review entries individually before issuing any payments. This means compliance platforms cannot simply trigger refund expectations based on the court order alone. Build in status polling against ACE entry summary data to track actual liquidation updates rather than assuming immediate effect.

For teams caching HTS duty rates, the IEEPA tariff removal does not affect MFN rates, Section 301 duties, or other tariff programs — only the emergency levies instituted under the International Emergency Economic Powers Act. Rate tables should be updated to exclude IEEPA calculations for new entries while preserving historical IEEPA rate data for audit and reconciliation purposes on legacy entries.

To integrate real-time HTS rate data and liquidation status tracking into your compliance workflows, contact us at /contact.html for a free 30-day trial of the TradeFacts.io API.