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IEEPA Tariff Refund Update: Atmus Filtration Case Dismissed, New Euro-Notions Orders

Alert

April 16, 2026

Judge Richard K. Eaton of the U.S. Court of International Trade (CIT) agreed to the plaintiff’s request for dismissal in the Atmus Filtration case. Now, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection (CBP) et. al., is before Judge Eaton; the plaintiff, Euro-Notions, is seeking injunctive relief and refunds for all IEEPA tariffs, including interest.

On April 7, 2026, Judge Eaton issued an order (April 7 Order) mirroring Atmus Filtration’s March 27, 2026, order (March 27 Order), which provided a path for refund of IEEPA duties imposed on unliquidated, liquidated, and liquidated and finalized entries.

Background

The March 27 Order, which outlined refund requirements for CBP, read as follows:

ORDERED that, with respect to any and all unliquidated entries that were entered subject to the IEEPA duties, U.S. Customs and Border Protection is hereby directed to liquidate those entries without regard to the IEEPA duties. Any liquidated entries for which liquidation is not finalized shall be reliquidated without regard to those duties. Any liquidated entries for which liquidation is finalized shall be reliquidated without regard to the IEEPA duties

Euro-Notions April 7 Order

The CIT has exclusive jurisdiction to hear IEEPA tariff refund cases, and the chief judge of the court designated Judge Eaton as the sole judge related to these matters. As such, on March 17, 2026, the Euro-Notions case was re-assigned to Judge Eaton.

On the heels of his March 27 Order in Atmus Filtration, Judge Eaton filed the April 7 Order in Euro-Notions that read:

ORDERED that, with respect to any and all unliquidated entries that were entered subject to IEEPA duties, U.S. Customs and Border Protection is hereby directed to liquidate those entries without regard to the IEEPA duties. Any liquidated entries for which liquidation is not final shall be reliquidated without regard to those duties. Any liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties.

Similar to Atmus Filtration, the order for immediate compliance is suspended as the CBP moves towards standing up its refund system.

The key takeaways from the April 7 Order are as follows:

Those entries yet to be liquidated are to be liquidated through CAPE functionality without imposing the IEEPA duties
Those entries liquidated (i.e., no more than 314 since logged in ACE) are to be reliquidated through the CAPE functionality without IEEPA duties
Those entries liquidated and finalized are to be reliquidated through CAPE functionality without IEEPA duties

We know from CBP’s March 31 declaration that the first phase of functionality will not process all three of these types of entries. CBP expects Phase I functionality to support the first (entries yet to be liquidated) and a portion of the second (entries liquidated within the last 80 days and not yet final) items listed above.

Though Atmus Filtration has been dismissed, CBP still owes the CIT an update on April 14, 2026, and its ability to have the Phase I CAPE functionality ready to go by the April 20, 2026, deadline.

Your Guide Forward

If you have questions about preserving your rights or about any other legal or trade implications that may exist, we recommend reaching out to appropriate legal counsel.

In addition to preparing as CBP suggests for proceeding with refund requests, we are advising our clients to prepare for its launch by gathering relevant data, examining potential liabilities, and modeling tax, transfer pricing, and financial statement impacts.

Cherry Bekaert established a cross-functional team of professionals to help advise and support our clients with the downstream effects when tariffs and tariff refunds impact tax, accounting, audit and financial reporting functions.

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