IEEPA Refund on Liquidated Entries

IEEPA refund on finally liquidated entries — we file Court of International Trade actions to recover duties on entries liquidated 80+ days ago.

Trembach Law Firm pursues recovery of IEEPA-based tariffs on finally liquidated entries — entries that liquidated more than 80 to 90 days ago and fall outside CBP's CAPE Phase 1 refund window. After the U.S. Supreme Court struck down the IEEPA tariffs 6-3 on February 20, 2026 (Learning Resources, Inc. v. Trump; Trump v. V.O.S. Selections), roughly 330,000 importers who paid an estimated $166 billion across more than 53 million entries became potentially eligible for refunds. But CBP has said it will not refund the IEEPA duties on finally liquidated entries — those liquidated more than 90 days, past its reliquidation power under 19 U.S.C. section 1501 — without an order from the U.S. Court of International Trade. Attorney Anatolii Trembach — California State Bar #349304, LL.M. in International Business and Economic Law (USC Gould), admitted to the U.S. Court of International Trade. Free consultation: (818) 514-7680.

What the July 2026 Court of International Trade orders changed

On July 15, 2026, the U.S. Court of International Trade began ordering CBP to refund IEEPA duties on plaintiffs' entries liquidated for more than 80 days, and on July 17 to reliquidate those finally liquidated entries without the IEEPA duties, with the same relief signaled across roughly 3,700 pending IEEPA cases. The orders reach only importers who filed suit. CBP's CAPE Phase 3, built for finally liquidated entries, is likewise available only to importers who are plaintiffs at the Court of International Trade. The government has appealed the portion of the order that would extend refunds to non-litigants.

Which recovery path fits your entry

Unliquidated entries and entries liquidated within 80 days are recoverable through CAPE in ACE and a protest under 19 U.S.C. section 1514 (filed within 180 days of liquidation on CBP Form 19). Finally liquidated entries — liquidated more than 90 days — sit outside CBP's section 1501 reliquidation window and require an action at the U.S. Court of International Trade under 28 U.S.C. section 1581 to compel reliquidation and refund. Refunds are paid as principal plus interest under 19 U.S.C. section 1505.

If you never filed suit, your options are closing

Importers who never filed a case have no confirmed, self-executing mechanism today. Three routes remain: (1) file your own action at the Court of International Trade to obtain an individualized reliquidation order; (2) monitor the pending motion for class certification intended to reach non-litigants; and (3) act before the two-year window to sue at the Court of International Trade under 28 U.S.C. section 2636(i) runs. CBP has already rejected about 15% of refund submissions, so how a claim is framed matters.

United States, California and Los Angeles importers

The Court of International Trade has nationwide jurisdiction, so importers anywhere in the United States can recover finally liquidated IEEPA duties without a New York firm. California is the largest import gateway in the country and holds an outsized share of the finally liquidated entries now in question. Los Angeles and Long Beach importers — goods cleared at the Port of Los Angeles (CBP Port 2704), the Port of Long Beach (CBP Port 2709), and LAX air cargo (CBP Port 2720), the busiest container gateway in the United States — paid a very large share of the IEEPA duties now finally liquidated.

Related pages: IEEPA Refund Attorney Los Angeles, Court of International Trade Litigation, Filing a CBP Protest, IEEPA Refund Eligibility, IEEPA Tariff Refund Hub, International Trade & Customs Law.

Filed Court of International Trade Actions

Trembach Law Firm is not only admitted to the U.S. Court of International Trade — it files its own IEEPA refund complaints there under 28 U.S.C. § 1581(i), with new complaints filed as importers sign ahead of CBP’s CAPE Phase 3. Anatolii Trembach is admitted to practice before the Court of International Trade and is licensed in California, State Bar #349304, verifiable at apps.calbar.ca.gov.

This matters for IEEPA refunds specifically. The Court of International Trade has ordered CBP to reliquidate and refund on plaintiffs’ entries, and CBP’s CAPE Phase 3 for finally liquidated entries is likewise available only to importers who are plaintiffs at the Court. An importer who never filed has no confirmed, self-executing mechanism. Choosing counsel who has actually filed at that court, rather than counsel who only describes the process, is therefore a practical question and not a marketing one.

Jurisdiction over these actions rests on 28 U.S.C. § 1581, and the window to sue runs under 28 U.S.C. § 2636(i). No particular outcome is promised or guaranteed.

Fees, Costs and Case Results

Representation in these matters is offered on a contingency basis covering attorney fees only: there is no attorney fee unless we recover, and clients remain responsible for case costs, such as court filing and service fees. The specific terms that apply to a matter are set out in the written fee agreement for that matter.

Where this site refers to a verdict, settlement or court order, that result was dependent on the facts of that case, and results will differ if based on different facts. Past results do not predict or guarantee the outcome of any other matter, and no particular outcome is promised or guaranteed.

Frequently Asked Questions

My entries have already finally liquidated — is it too late to recover the IEEPA tariffs?

Not necessarily, but the path is narrower. Once an entry has been liquidated for more than 90 days it is "finally liquidated" and falls outside CBP's ordinary 90-day reliquidation authority under 19 U.S.C. § 1501. CBP has taken the position that it will not refund IEEPA duties on those entries without a court order. The confirmed way to force that refund is to be a plaintiff at the U.S. Court of International Trade: on July 15, 2026 the CIT began ordering CBP to reliquidate finally liquidated entries — without the IEEPA duties — for importers who filed suit, and has signaled the same relief across the roughly 3,700 pending IEEPA cases. If your entries are finally liquidated, filing your own CIT action is currently the surest way to preserve and recover the refund with interest.

What exactly is a "finally liquidated" entry, and why does the 80-day / 90-day line matter?

Liquidation is CBP's final computation of the duties owed on an entry. CBP can reliquidate on its own initiative for 90 days after liquidation (19 U.S.C. § 1501); after that the entry is "finally liquidated" and CBP loses that unilateral power. That is why CAPE Phase 1 only reached entries liquidated within 80 days of the refund submission — CBP could still reach those administratively. Entries liquidated longer ago sit outside that window, and the July 15, 2026 CIT order specifically directs CBP to refund IEEPA duties on plaintiffs' entries that have been liquidated for more than 80 days. If your entries crossed that line, an administrative fix alone will not reach them.

What is CAPE, and why did Phase 1 leave my older entries out?

CAPE is CBP's consolidated electronic IEEPA-refund tool inside ACE. It rolled out in phases: Phase 1 (launched April 20, 2026) covered unliquidated entries and entries liquidated within 80 days of submission; Phase 2 (June 29, 2026) added certain reconciliation entries; and Phase 3 (which CBP, in a September 15, 2026 declaration to the Court of International Trade, set to deploy on October 6, 2026) is the phase built for finally liquidated entries — but Phase 3 is available only to importers who filed suit at the Court of International Trade. So if your entries finally liquidated and you never sued, no CAPE phase currently returns your money on its own. That is the gap this page exists to close.

I did not file a lawsuit. Do I have any way to recover IEEPA duties on finally liquidated entries?

Right now importers who did not sue have no confirmed, self-executing mechanism. The government has appealed the part of the CIT order that would extend refunds to non-litigants, arguing CBP cannot refund finally liquidated entries without a valid court order. Three things can still protect you: (1) filing your own CIT action so you can seek an individualized reliquidation order; (2) monitoring the pending motion for class certification, which is intended to reach non-litigants; and (3) acting before the two-year window to sue at the Court of International Trade (28 U.S.C. § 2636(i)) runs. Waiting for the appeal to resolve can mean losing the right to sue at all. Call (818) 514-7680 and we will tell you where each of your entries stands.

Will the refund include interest?

Yes. When CBP refunds excess duties it pays interest on the amount refunded (19 U.S.C. § 1505). The IEEPA reliquidations CBP has processed so far were reported as refunds of principal plus interest — on the order of $35 billion across the millions of entries already reliquidated without IEEPA duties. We calculate the IEEPA principal and the interest that runs with it so you claim the full amount, not just the tariff.

Do I need a customs attorney, or can my broker or CBP handle this?

A customs broker can file entries, and CAPE handles the simple, still-open cases. But finally liquidated entries turn on litigation: filing and prosecuting an action at the U.S. Court of International Trade, framing the § 1581 jurisdictional basis, and obtaining a reliquidation order are the practice of law, not entry filing. CBP has already rejected roughly 15% of refund submissions, so accuracy matters. Attorney Anatolii Trembach holds an LL.M. in International Business and Economic Law (USC Gould) and is admitted to the U.S. Court of International Trade; we work alongside your broker so nothing is lost between the entry file and the courtroom.

How much does it cost to recover an IEEPA refund on finally liquidated entries?

Trembach Law Firm offers a free initial consultation and refund-eligibility review and handles IEEPA duty-refund recovery on a contingency basis — you pay a percentage of what we actually recover. Call (818) 514-7680 for a same-day review of which of your entries are finally liquidated and what recovery each one supports.

Contact Trembach Law Firm

Trembach Law Firm, APC

27001 Agoura Road, Suite 350, Calabasas, CA 91301

Phone: (818) 514-7680

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