You Still Have Options: Recovering IEEPA Tariff Refunds After the CAPE and Protest Deadlines Have Passed

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The Supreme Court struck down IEEPA tariffs in February 2026, but many importers who missed the CAPE refund window or the 180-day protest deadline wrongly believe they have no recourse. A separate path through the U.S. Court of International Trade under 28 U.S.C. ยง 1581(i) remains open, offering a two-year statute of limitations โ€” but acting quickly is critical before entry-specific deadlines expire permanently.

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New Section 301 Tariffs on Imports from 60 Economies Now in Effect

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Effective July 24, 2026, the USTR imposed new Section 301 tariffs of 10% or 12.5% on imports from 60 trading partners covering roughly 99.4% of U.S. imports. The action includes a multi-tier tariff structure, exemptions for certain food, pharmaceutical, energy, and aerospace products, and a narrow in-transit window. Importers and companies relying on international supply chains should assess their exposure immediately.

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IEEPA Refunds for Liquidated Entries: What Importers Must Do Now to Preserve IEEPA Refund Rights

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A July 15, 2026 U.S. Court of International Trade order establishes a refund framework for importers who paid International Emergency Economic Protection Act (IEEPA) tariffs on already-liquidated entries. The relief applies primarily to importers who have filed suit, as CBP maintains it cannot independently reliquidate finalized entries without a court order. Importers with liquidated entries…

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