Court Resumes IEEPA Tariff Refund Process After Atmus Dismissal
Summary
Judge Richard Eaton of the Court of International Trade dismissed the Atmus Filtration case, causing his March 4 order and the DOJ appeal window to lapse. He quickly lifted the stay on Euro Notions Florida Inc. v. U.S., reaffirming that all importers of record are entitled to IEEPA tariff refunds under the Supreme Court's ruling. The new order directs CBP to refund and liquidate entries and resets the DOJ appeal deadline to June 6.
What changed
The Atmus Filtration case that Judge Eaton had been using to oversee the IEEPA tariff refund process was voluntarily dismissed by the plaintiff before DOJ filed an answer, causing his March 4 order and the DOJ appeal window to fall away. The judge immediately lifted the stay on Euro Notions Florida Inc. v. U.S., reiterating that all importers of record whose entries were subject to IEEPA tariffs are entitled to refunds under the Supreme Court's decision and confirming CIT's exclusive jurisdiction over such claims.
Importers and their customs brokers should prepare for CBP to process refunds and liquidate or reliquidate entries. CBP must complete liquidation for entries that have been liquidated but are not yet final, and must reliquidate entries where liquidation is final. The DOJ appeal deadline is now June 6, providing a defined timeline for the process to continue. CBP's first phase of CAPE is scheduled to launch April 20, potentially streamlining the refund process.
What to do next
- Monitor CBP CAPE system launch on April 20
- Track further court orders in Euro Notions Florida Inc. v. U.S.
- Ensure import entry documentation supports potential refunds
Archived snapshot
Apr 13, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 13, 2026 // Trade Report
Tariff Refund Process Advances Despite Litigation Change
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The case that Judge Richard Eaton of the Court of International Trade had been using to oversee the IEEPA tariff refund process (Atmus Filtration) was voluntarily dismissed by the plaintiff last week for unspecified reasons. In a March 4 order in Atmus Eaton had directed U.S. Customs and Border Protection to refund all IEEPA tariffs immediately, though he then suspended the immediacy requirement to allow CBP to develop its Consolidated Administration and Processing of Entries program. CBP has been filing weekly status reports on CAPE and expects to deploy the first phase of the system on April 20.
Because the dismissal of the case occurred before the Department of Justice filed an answer or a summary judgment motion, the judge had no discretion to keep the case alive. As a result, Eaton’s March 4 order—and the Department of Justice’s ability to appeal it—also fell away.
However, the judge moved quickly to keep the refund process on track by lifting the stay on a similar case, Euro Notions Florida Inc. v. U.S. (all cases challenging the IEEPA tariffs had been stayed pending Atmus). He then issued a new order in that case reiterating that “all importers of record whose entries were subject to IEEPA tariffs are entitled to the benefit of” the Supreme Court’s decision overturning those tariffs, signaling universal application. He also reaffirmed that the CIT has exclusive jurisdiction over IEEPA tariff refund claims and that he will be the sole judge assigned to hear them.
The new order directs CBP to provide refunds and to liquidate any and all unliquidated entries. For entries that have been liquidated but are not yet final, CBP must complete liquidation, and where liquidation is final, CBP must reliquidate the entries. The new order also resets to June 6 the deadline for the DOJ to appeal.
In the meantime, CBP has announced that it will launch the first phase of CAPE on April 20. Click here for additional information from CBP.
Copyright © 2026 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.
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