On March 4, 2026, Judge Richard Eaton of the U.S. Court of International Trade issued what may be the most consequential order in the IEEPA tariff litigation to date. In Atmus Filtration, Inc. v. United States, the CIT ordered CBP to liquidate all unliquidated IEEPA entries without assessing IEEPA duties and to reliquidate any entries where liquidation is not yet final — also without IEEPA duties.
In practical terms, this is an order for universal refunds. For a comprehensive walkthrough of the entire refund process, see our complete guide to IEEPA tariff refunds. It follows the February 20, 2026, Supreme Court ruling in Learning Resources, Inc. v. Trump that invalidated all IEEPA tariffs and establishes the procedural framework for how refunds will be processed.
What the order requires
The CIT directed CBP to take two specific actions. First, all unliquidated entries — those still within the approximately 314-day processing window — must be liquidated without any IEEPA duty assessment. This means the duties are never finalized, and any deposits already collected must be returned.
Second, any entries that have been liquidated but where the 180-day protest period has not yet expired must be reliquidated without IEEPA duties. This effectively reopens those entries and triggers refunds for duties already paid.
The order extends relief to all importers of record, not only those who filed suit. Judge Eaton explicitly stated that IEEPA tariff relief applies universally. This is a critical distinction: importers do not need to have been party to the litigation to benefit.
The CAPE portal
During the March 6 closed hearing, CBP informed the court that it cannot process refunds through its existing systems at the required scale. CBP has approximately 2,500 staff members available to process over 53 million affected entry lines. Manual processing at this volume would take years.
CBP proposed building a new automated system within the Automated Commercial Environment — now referred to as the CAPE (Claims Automation and Processing Engine) portal. CBP requested 45 days from the March 11 filing date to build and launch this system, which would place the target launch around late April 2026.
The CIT paused enforcement of its order while CBP builds the CAPE system, but has signaled it will not tolerate extended delays. As of March 19, CBP filed a status update reporting the following progress: Claim Portal 73% complete, Mass Processing 45% complete, Review and Liquidation 80% complete, and Refund component 63% complete.
What this means for importers
The CIT order establishes two critical facts. First, refunds are coming — the legal question is settled. Second, CBP will process claims in filing order through an automated system that does not yet exist. Our CAPE queue position analysis details how filing order affects your refund timeline.
This creates a clear first-mover advantage. Companies that have their data validated and ready to submit the moment CAPE launches will be processed first. Companies that wait until CAPE is live to begin preparing their data will join a queue that is already hundreds of thousands deep.
The 45-day build window creates additional urgency
If CBP fails to meet the deadline or the CAPE system encounters problems at launch, the CIT has indicated it may take more aggressive action — potentially including contempt proceedings. Importers should not rely solely on the automated process and should continue filing protective protests on liquidated entries under 19 U.S.C. Section 1514.
The documentation requirements for CAPE submission are expected to mirror current CBP entry summary data formats. Importers should ensure they have ES-003 reports exported from the ACE portal covering the full IEEPA period (February 4, 2025, through February 24, 2026). Our documentation guide provides a complete checklist of required fields and reports.
Filing position matters
CBP has confirmed that CAPE will process claims in submission order. Early, validated submissions with complete ES-003 data exports will be processed first. Incomplete or manually prepared submissions will be routed to secondary review queues, which may add months of delay. Claims filed after the initial surge will face the longest wait times.
For importers with significant IEEPA exposure — particularly those with annual import values above $2 million — the difference between filing in the first wave and filing in the third wave could mean 12-24 months of additional delay in recovering capital. The cost of waiting analysis quantifies this impact using time-value-of-money calculations.
Alternatives to the CAPE queue
Importers who cannot afford to wait 18-36 months for CAPE processing have two alternatives. First, for entries that are still within the protest window, filing a formal protest under 19 U.S.C. Section 1514 followed by a request for accelerated disposition may yield faster results than CAPE for individual entries.
Second, claim assignment through institutional buyers provides non-recourse capital within 14-21 business days, entirely bypassing the CAPE queue. Our government filing vs. immediate capital comparison provides a framework for evaluating which approach makes sense for different portions of your claim portfolio.
Next steps
Request a confidential Impact Assessment to determine your total IEEPA exposure, map the liquidation status of every affected entry, and identify the optimal recovery path for each one. The assessment is provided at no cost and is covered by mutual NDA.
Customs brokers and trade attorneys advising multiple importers on CIT order compliance may also benefit from the partner referral program. For importers with China-specific IEEPA exposure, the China tariff refund guide provides rate-specific analysis, and the eligibility screening tool offers an initial qualification check.
