IEEPA Ends, 15% Begins

Macro shot of a customs declaration form on a shipment, international harbor scene in the backdrop

U.S. Customs and Border Protection has formally announced that it will stop collecting tariffs imposed under the International Emergency Economic Powers Act effective 12:01 a.m. EST Tuesday. The decision follows last week’s U.S. Supreme Court ruling that the IEEPA-based tariffs were unlawful.

In a Cargo Systems Messaging Service notice issued to the trade community, CBP confirmed that all tariff codes associated with prior IEEPA-related executive orders will be deactivated. This marks the operational end of those collections at U.S. ports of entry.

The halt in collections comes more than three days after the Supreme Court decision and coincides with the implementation of a new 15 percent global tariff under a different statutory authority. The administration has moved quickly to replace the invalidated framework with a new trade measure, signaling that tariff policy remains firmly in place even if the legal mechanism has changed.

CBP’s notice did not explain why collections continued for several days after the Court’s ruling, nor did it provide any immediate details regarding the refund process for importers who paid duties under the now-invalid authority.

According to economic modeling estimates cited by Reuters, more than $175 billion in U.S. Treasury revenue generated under the IEEPA tariffs may now be subject to refund claims. Economists estimate that the IEEPA measures had been producing more than $500 million per day in gross tariff revenue. That level of revenue underscores the scale of the administrative task ahead. If a substantial portion of those funds are refunded, CBP and the Court of International Trade will need to establish a structured process for claims, validation, and disbursement.

At present, there is no formal refund mechanism announced. Trade professionals anticipate that guidance will be issued through additional CSMS messages in the coming days or weeks. CBP stated it will provide further instructions to the trade community as appropriate. For importers and brokers, this creates a transitional window. Collections under IEEPA have stopped, however the refund pathway remains undefined.

While IEEPA tariff codes are being deactivated, the administration’s newly announced 15 percent global tariff is taking effect under a separate legal authority. CBP confirmed that the halt applies only to IEEPA-related tariffs and does not impact duties imposed under Section 232 national security provisions or Section 301 trade enforcement statutes. The Supreme Court ruling addressed only IEEPA-based tariffs. Other trade remedies remain fully intact.

The immediate implication is that importers will likely see a shift in tariff coding rather than a complete elimination of duty exposure. From a cash flow perspective, many shipments may continue to face additional tariff layers, albeit under a revised statutory structure.

For importers, the key questions now are procedural. How will refund claims be submitted. Will claims require entry-by-entry filing. Will CBP automate portions of the process. What documentation standards will apply. How will previously liquidated entries be treated.

The scale of filings could be enormous. Each entry that included IEEPA-based duties may require individual review. Depending on how CBP structures the process, this could resemble a mass protest, post summary correction campaign, or a newly designed electronic refund protocol.

For customs brokers, this represents both workload pressure and opportunity. Firms will need to assess historical entry data, quantify potential refund amounts, and determine staffing capacity to manage claims at scale. Speed will matter, but accuracy will matter more. Large-scale refund claims inevitably increase audit scrutiny.

The estimated $500 million per day previously generated by IEEPA tariffs illustrates why this issue is economically significant. A sudden halt removes a substantial revenue stream. The administration’s rapid pivot to a 15 percent global tariff suggests an effort to maintain fiscal and trade leverage continuity. Financial markets have thus far reacted calmly, indicating that investors anticipated an alternative tariff framework would follow the Court’s decision. The broader trade environment remains dynamic rather than stabilized.

Several developments are likely in the near term, including formal refund guidance from CBP through CSMS, clarification from the Court of International Trade regarding jurisdiction and procedure, potential legislative response from Congress, and further administrative adjustments to the new tariff authority. The next few weeks will define the practical impact more than the legal headline.

PNG is closely monitoring these developments and assessing operational implications for our customers. We are reviewing the CBP CSMS communications and awaiting additional procedural guidance before advising on refund filing strategy. PNG also awaits recommendations and best-practice guidance from the National Customs Brokers and Forwarders Association of America, which is expected to provide direction to the trade community regarding documentation standards and claim processing. We will continue to keep customers informed as regulatory instructions are clarified and as implementation details become available.

IEEPA tariff collections have stopped. A new 15 percent global tariff has begun. Refund exposure could exceed $175 billion. The administrative framework for recovery remains undefined. This is not the end of tariff policy. It is a structural reset. Organizations that prepare early, document thoroughly, and move deliberately will navigate this transition more effectively than those who wait for complete certainty.

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