A federal trade court has ordered the refund of duties imposed under now-invalidated Executive Orders, directing US Customs to reliquidate millions of entries following a landmark Supreme Court decision that declared the tariffs unlawful.
Judge Richard K. Eaton of the United States Court of International Trade issued an order on 4 March 2026, requiring US Customs and Border Protection to refund duties collected under Executive Orders issued through the International Emergency Economic Powers Act (IEEPA).
Earlier, Atmus Filtration, Inc. filed the lawsuit seeking monetary relief and refunds of all payments made under these orders, including reliquidation of entries with interest.
The ruling follows the Supreme Court’s decision on 20 February 2026 in Learning Resources, Inc. v. Trump, which declared IEEPA duties unlawful. This decision benefits all importers whose entries were subject to these duties. While the Supreme Court’s 2025 Trump v. CASA, Inc. ruling prohibited universal injunctions, Judge Eaton clarified that this limitation does not apply to the Court of International Trade, which operates under a different statutory authority.
The Court of International Trade was established in 1980 under the Customs Courts Act with national jurisdiction and exclusive authority over such trade disputes. The Supreme Court recently acknowledged this exclusive jurisdiction in the Learning Resources case. Judge Eaton emphasised that constitutional requirements mandate uniformity in duties and imposts throughout the US, and noted he is the sole judge handling IEEPA duty refund cases.
The court directed Customs and Border Protection to liquidate all unliquidated entries without applying IEEPA duties. Additionally, any liquidated entries not yet final must be reliquidated, excluding these duties, ensuring efficient resolution and equal treatment for all affected importers.
On 20 February 2026, the US Supreme Court ruled 6–3 in Learning Resources v. Trump that Donald Trump exceeded his authority under the International Emergency Economic Powers Act of 1977 by imposing broad global tariffs. The decision invalidated earlier emergency tariffs ranging from 10% to 50%. Following the ruling, the US began applying a new flat 10% global import tariff starting 25 February 2026.
