Refund Process for IEEPA Tariffs Moves Forward

On March 2, 2026, the U.S. Court of Appeals for the Federal Circuit ordered the mandates in the V.O.S. Selections appeals to issue forthwith. In plain English, the appellate stay that had paused enforcement is now lifted.

The cases return to the U.S. Court of International Trade for remedial proceedings. This is a major procedural milestone for importers who paid tariffs under the International Emergency Economic Powers Act.

Last month, the Supreme Court of the United States held in Learning Resources v. Trump that IEEPA does not authorize the President to impose tariffs. That decision affirmed the earlier Federal Circuit ruling invalidating the emergency tariff regime.

Until now, implementation was effectively frozen. With the mandate issued, the Court of International Trade can now move forward on:

- Remedial briefing

- Reliquidation procedures

- Refund mechanics

- Scope of eligible entries

This is the procedural green light importers have been waiting for.

The CIT will set a schedule for briefing on remedies. Key questions remain:

- Will refunds be automatic or require action by importers

- How broadly will the ruling apply

- What documentation will be required

- Whether protests or protective filings are necessary

The government has not yet issued formal guidance on refund administration. That process is expected to develop quickly now that the mandate has issued.

Importers who paid IEEPA tariffs should not assume refunds will simply arrive.

Customs law is procedural. Rights must often be preserved. Documentation must be organized. Entry data must be validated. Refund exposure must be calculated precisely.

This is not the time to wait.

Evana is already preparing clients for this next phase.

We ingest ACE data directly.

We quantify exact IEEPA exposure by entry.

We identify additional refund opportunities beyond IEEPA.

We prepare documentation so claims can be filed immediately when guidance is issued.

There are hundreds of thousands of affected importers. The administrative process will not move instantly once filings begin.

Brands that are organized first will get paid first.

If you paid IEEPA tariffs in the last year, now is the time to prepare.

Book a call with Evana and make sure your refund is secured before the rush begins.