The Government Is Actively Blocking IEEPA Tariff Refunds
CBP is rejecting PSC submissions and suspending protest filings. The administrative pathway has effectively been closed off, pushing everything into the courts.
Since February, practitioners have reported a coordinated pattern: CBP is rejecting PSC submissions on technical grounds, suspending protest decisions, and delaying liquidations in ways that extend the pre-refund period indefinitely. The administrative pathway is not formally closed, but in practice it is congested.
What we are seeing in the field
- PSC rejections citing documentation standards not previously enforced.
- Protest decisions held past statutory timelines with no allowable denial that starts the CIT clock.
- Informal guidance directing CBP personnel to defer IEEPA-related refund processing.
The tactical implication
File PSC and protest anyway — to create the administrative record and trigger the deemed denial clock. Pair the filing with a CIT strategy so that the moment the administrative pathway deems out, the litigation pathway is ready to go. Treating administrative and litigation as sequential is how importers lose the window.
TariffAuditLabs is a tariff recovery service, not a law firm. We prepare Post Summary Corrections and CBP protests and file them through your licensed customs broker. For Court of International Trade matters, we refer clients to independent CIT-admitted trade counsel; those engagements are contracted and priced directly with counsel and we do not share legal fees. This article is general information about IEEPA refund recovery and is not legal advice for any specific importer. Deadlines vary by entry; confirm your position with qualified counsel before relying on anything here.
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