On December 15, 2025, the Court of International Trade announced that the liquidation of an entry is not sufficient grounds to bar the Court from granting refunds should the International Emergency Economic Powers Act (IEEPA) Tariffs be found unlawful. 

Notably, this ruling currently ONLY applies to companies with active lawsuits filed, and the Court has warned that if your goods have already been liquidated, a simple protest will likely be insufficient to receive a refund, and working through the legal system is likely the only way forward. 

For those importers who believe they will be entitled to a refund should the IEEPA tariffs be struck down, it is recommended that you work closely with a trade lawyer or Customs broker when determining the best course, as a two-pronged approach of legal and standard protest actions may be required should refunds be made available. 

Whether refunds will be available is inextricably tied to whether the tariffs are deemed unlawful, and as such, this is a developing situation that could very easily be affected by future decisions.