IEEPA tariff refunds

What was held, and what stopped

In Learning Resources, Inc. v. Trump, No. 24-1287, decided 20 February 2026 by six votes to three, the Supreme Court held that the International Emergency Economic Powers Act does not authorize the imposition of tariffs. Customs and Border Protection deactivated the affected headings in ACE by CSMS 67834313, and the duties stopped being collected for entries made on or after 24 February 2026.

The decision reached every duty imposed under the statute: the border actions on goods of Canada, Mexico and China from early 2025, and the country-wide reciprocal schedule that followed. It did not reach Section 232, Section 301 or Section 338, which rest on other statutes and continue to be collected. The status note sets out what is in force today.

Duties collected under an authority later held invalid were collected without authority. That is a different position from duties collected under an action that has since expired on its own terms, which is why the Section 122 surcharge that replaced the IEEPA duties on 24 February 2026, and lapsed on 24 July, is reported on this page but never counted with them.

Source: WHITE HOUSE, Learning Resources, Inc. v. Trump, No. 24-1287 (U.S. Feb. 20, 2026), published 2026-02-20. Verified 2026-09-06.

Assess a filed entry export

An entry summary states the Chapter 99 headings reported on each line and the duty paid against them. The assessor reads those lines and sums the duty reported under the affected headings, on entries dated inside the collection window. It works from what was filed, not from an estimate of what might have been paid. Where a line reports an affected heading without breaking duty out by heading, the line is counted at zero and flagged, so the total is a floor.

The posture of an entry

The amount paid is one fact. Whether it can still be reached is another, and it turns on the entry rather than on the duty. An entry that has not liquidated is ordinarily corrected by post-summary correction. An entry that has liquidated is reached, if at all, by protest under 19 U.S.C. 1514, and the protest period runs from liquidation and is limited. Entries beyond the protest period are in a different position again, and the scope of any relief for them is what the litigation following the decision is about.

The assessor marks lines on entries recorded as liquidated and reports the earliest and latest entry date it read, which are the two facts a broker needs first. It does not state a deadline for any entry, because the liquidation date is on the filing and not in the export the assessor reads.