The U.S. Court of International Trade (CIT) has paused — though not withdrawn — a sweeping order requiring U.S. Customs and Border Protection (CBP) to refund all duties imposed under the International Emergency Economic Powers Act (IEEPA). The pause, issued March 6, 2026, reflects the court’s acknowledgement of the practical limits on CBP’s ability to execute immediate refunds. Nonetheless, the court’s core conclusion has not changed: IEEPA duties were unlawful and must ultimately be unwound.

The March 6 order followed an extraordinary directive issued just two days earlier. On March 4, CIT Judge Richard K. Eaton ordered CBP to liquidate all unliquidated entries and reliquidate any liquidated entries that are not yet final, effectively requiring refunds to every importer whose entries were assessed IEEPA tariffs. The case at issue (Atmus Filtration Inc. v. United States) was filed after the Supreme Court’s decision last month in Learning Resources Inc. v. Trump, seeking a preliminary injunction preventing further collection of IEEPA tariffs by CBP and an immediate refund of the tariffs paid.

The government responded to the March 4 order arguing that immediate compliance was not possible. In a March 6 declaration, CBP detailed the unprecedented scale of the task: it would require refunds paid by more than 330,000 importers, affecting 53 million entries, resulting in the return of roughly $166 billion. CBP argued that its Automated Commercial Environment (ACE) system cannot readily identify IEEPA-duty entries or halt weekly liquidations without risking errors in other trade remedies. CBP’s declaration estimates that processing refunds manually would require more than 4 million hours to complete the refund process for all entries with IEEPA duties. CBP proposed that the government develop new functionality within the ACE system to process IEEPA duty refunds in a more efficient manner. CBP is “making all possible efforts” to have the new functionality ready for use in 45 days.

Judge Eaton’s March 6 order suspends the prior directive but only “to the extent that it directs immediate compliance,” expressly leaving the underlying refund obligation in place. The court set no firm deadline, effectively granting CBP limited breathing room to develop an automated refund process while preserving importers’ entitlement to relief.

For importers, the takeaway is straightforward even if the timeline is not: refunds of IEEPA duties are coming. But the uncertainty regarding when CBP will be in a position to process the refunds — and when refunds will actually be received — remains. Importers should ensure they have completed CBP’s required electronic refund registration process as soon as possible to avoid additional delays in refund processing and continue to monitor the mechanics of the refund process as they take shape.

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