The recent developments surrounding IEEPA tariffs in the United States are being further clarified through additional procedural steps and the implementation of concrete measures.

The U.S. Court of International Trade has further clarified and amended its earlier decisions regarding the reimbursement of IEEPA tariffs. This potentially creates broad refund rights for importers. The likelihood of these being enforced is considered high, although the volatile and shifting political landscape in the United States, as observed over the past year, remains a factor to take into account.

What should you do in practice?
You should reassess existing import transactions, determine whether you are entitled to a refund, and then submit a claim through your broker or internal compliance team in ACE or via the CAPE workflow once it becomes fully operational.