On May 27, 2026, following a closed-door conference in Euro-Notions Florida v. United States (CIT # 25-00595), Judge Eaton issued two orders requiring U.S. Customs and Border Protection (CBP) to explain the government's position on issuing IEEPA refunds for all entries—including those liquidated beyond the 90-day statutory reliquidation period.
The First Order is related to Euro-Notions Florida v. United States. In this order, the Court of International Trade (CIT) addressed CBP's Consolidated Administration and Processing of Entries (CAPE) program, launched April 20, 2026, and expressed concern that the government has not proposed a solution for entries excluded from Phase 1—particularly those already finally liquidated or otherwise ineligible.
The second Order is related to V.O.S. Selections, Inc. v. United States. In V.O.S. Selections (CIT # 25-00066), Judge Eaton sua sponte lifted the stay and ordered parties to show cause why the Court should not remove the suspension of immediate compliance.
the question is relevant, given that prior order (March 2026) required CBP to liquidate/reliquidate all IEEPA-duty entries without regard to those duties, while government's position was to refund only importers who filed CIT complaints with court-ordered refunds. Now the CIT admits refunds for all importers who paid IEEPA duties—including those with final liquidations, regardless of whether they sued.