On June 3, 2026, President Trump issued an executive order (“EO”) directing U.S. Customs and Border Protection (“CBP”) to reform many of its enforcement provisions. Titled “Strengthening Customs Enforcement,” the EO targets preventing the importation of unlawful and dangerous goods, tightening eligibility and identification requirements for importers of record (“IORs”), and ensuring compliance with Federal laws and timely collection of duties.
On May 27, 2026, following a closed-door conference in Euro-Notions Florida v. United States (CIT # 25-00595) (“Euro-Notions”), Judge Eaton issued two (2) orders which will require U.S. Customs and Border Protection (“CBP”) to explain the Government’s position on issuing IEEPA refunds for all entries, including those that have liquidated beyond the statutory reliquidation period
This update covers three key developments this week: (1) U.S. Customs and Border Protection (“CBP”) filed its latest status update in Euro-Notions on April 14, 2025; (2) Judge Eaton thereafter issued another order; and (3) next steps / recommendations for importers.
U.S. Customs and Border Protection (“CBP”) issued guidance on how importers need to report and classify goods subject to the revised steel, aluminum, and copper tariffs announced by the Trump Administration on April 2, 2026. We encourage importers to review the list of HTS number affected by the metal tariffs to ensure compliance with the below reporting requirements.
On March 31, 2026, Brandon Lord, the Executive Director of the U.S. Customs and Border Protection (“CBP” or “Customs”) Trade Programs Directorate, Office of Trade, filed a status update (the “Declaration”) with the Court of International Trade (“CIT”) further outlining Customs’ progress in developing the Consolidated Administration and Processing of Entries (CAPE) functionality within ACE. CAPE has four integrated components: Claim Portal, Mass Processing, Review and Liquidation/Reliquidation, and Refund.
On March 19, 2026, Brandon Lord, the Executive Director of U.S. Customs and Border Protection, filed a status update with the U.S. Court of International Trade (“CIT”) outlining CBP’s progress in developing a new Automated Commercial Environment (“ACE”) functionality intended to support refunds of tariffs that were imposed under the International Emergency Economic Powers Act (“IEEPA”).
On March 6, 2026, Brandon Lord, U.S. Customs and Border Protection’s (“CBP”) Executive Director for Trade Programs, filed a declaration with the U.S. Court of International Trade (“CIT”) in the ongoing Atmus Filtration, Inc. v. United States case and following up on an order issued by Judge Richard Eaton of the CIT issued earlier this
Effective February 6, 2026, Customs and Border Protection (“CBP”) will issue refunds electronically via Automated Clearing House (“ACH”). This rule change will affect all refunds, subject to limited exceptions (e.g., certain emergency payments, transactions involving national security or law enforcement concerns, transactions involving individuals who do not have access to banking services or electronic payment systems, etc.). FR Document 2025-24171. Also this rule will apply to all importers, brokers, filers, sureties, service providers, facility operators, foreign trade zone operators, and carriers as well as designated third parties listed on a CBP Form 4811. In short, absent a waiver, after February 5, 2026 CBP will not issue refunds by check.
CBP announced on October 6, 2025, that it will not issue refunds or any payments related to drawback claims, post-summary corrections and protests during the government shutdown which began on October 1, 2025.