Executive summary

On 4 March 2026, in Atmus Filtration, Inc. v. United States (Ct. No. 26-01259), the United States (US) Court of International Trade (CIT) ordered US Customs and Border Protection (CBP) to liquidate all unliquidated entries that were subject to tariffs imposed under the International Emergency Economic Powers Act (IEEPA) without regard to IEEPA duties. The CIT also ordered reliquidation, without IEEPA duties, of entries for which liquidation is not yet final.

In Atmus Filtration, the plaintiff importer had challenged duties imposed under various executive orders issued under IEEPA and sought, among other relief, refunds and reliquidation of its entries, where necessary. Entry liquidation typically occurs 314 days after the date of entry, when CBP issues its final calculation of duties owed on imported merchandise, making the assessed amount binding unless a formal protest is filed.

The CIT noted that the plaintiff's entries are among millions that were entered subject to IEEPA duties, which the US Supreme Court held unlawful in Learning Resources, Inc. v. Trump (20 February 2026). On 4 March 2026, CIT stated that all importers of record whose entries were subject to IEEPA duties are entitled to the benefit of the Learning Resources decision.

For more on the Supreme Court's decision, see EY Global Tax Alert, US Supreme Court rules IEEPA does not authorize presidents to impose tariffs, dated 20 February 2026.

The CIT's order

The CIT expressly directed CBP to liquidate all unliquidated entries that were entered subject to IEEPA duties without regard to IEEPA duties.

Further, the CIT ordered any entries that have been liquidated, but for which liquidation is not final, to be reliquidated without regard to IEEPA duties.

Scope and jurisdiction

The CIT addressed the Government's likely reliance on the Supreme Court's decision in Trump v. CASA, Inc., which held that "universal injunctions are impermissible," and explained why that holding does not apply here. The CIT emphasized its establishment under the Customs Courts Act of 1980, its national geographic jurisdiction (28 U.S.C. section 1581), and its exclusive subject matter jurisdiction over this type of claim — recently acknowledged by the Supreme Court in Learning Resources. The CIT underscored Congress's intent for uniformity and expeditious resolution of import-related disputes and the Constitution's requirement that duties be uniform throughout the United States.

The order also noted that the Chief Judge has indicated that Judge Richard K. Eaton is "the only judge who will hear cases pertaining to the refund of IEEPA duties," eliminating the risk of conflicting rulings within the CIT.

What this means for businesses

This order provides relief for entries affected by IEEPA tariffs, directing CBP to remove IEEPA duties at liquidation and to reliquidate entries for which liquidation is not yet final. Importers should expect CBP implementation steps to follow and prepare to align internal financial records. The order does not address entries for which liquidation is already final.

Actions to consider

Actions for businesses to consider, depending on their specific situations, include:

• Compile entries that were subject to IEEPA duties and determine status (unliquidated, liquidated and, when liquidated, those within 180 days of liquidation when a protest may still be filed).
• Analyze entry data and documentation to quantify and track potential refunds for internal financial alignment.
• Monitor for CBP operational guidance and timelines implementing the CIT's order and be prepared to coordinate with brokers to update entry instructions.
• For entries with final liquidation, consult counsel on options considering the order's scope.