TradeLane

In international trade, outcomes are shaped not only by the movement of goods, but also by the data behind them. This dynamic is evident in President Trump’s recent Executive Order (E.O.) on Strengthening Customs Enforcement which points to a systemic shift in the U.S. import compliance environment. While much of the initial commentary has centered on the stricter treatment of foreign importers of record (IORs), including restrictions on informal entries, tighter conditions for formal entries, and limits on the use of continuous bonds, that is only part of this broader structural reset.

U.S. Customs and Border Protection (CBP) has released important interim guidance addressing a key operational challenge for the trade community: how to handle reconciliation filings for import entries that contain IEEPA duties. These updates can be found in the FAQ section on CBP’s main IEEPA duty refunds page.

International Emergency Economic Powers Act (IEEPA) Duty Refunds | U.S. Customs and Border Protection

In a May 29 filing, the US Department of Justice (DOJ) confirmed its intent to appeal the US Court of International Trade (CIT)’s sweeping order requiring refunds of IEEPA duties. The government’s central argument is that the CIT exceeded its authority by directing refunds for entries that are “finally liquidated”—generally those more than 90 days past liquidation—particularly for importers that have not filed suit.

U.S. Customs and Border Protection (CBP) has activated the Consolidated Administration and Processing of Entries (CAPE) tool in the Automated Commercial Environment (ACE), creating a formal path for importers to seek refunds of duties imposed under the International Emergency Economic Powers Act (IEEPA). While CAPE is designed to streamline and consolidate refunds, importers retain key responsibilities that must be addressed before any refund can be issued.

Understanding and preparing for those responsibilities is critical to avoiding delays and missed recoveries.

On October 30, 2025, the White House suspended the implementation of the BIS 50% rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities for one year, starting on November 10, 2025. This delay is due to a reciprocal agreement with China. The rule would have extended export-licensing requirements to companies' majority-owned by parties on the Entity List, Military End-User List, or certain OFAC Specially Designated Nationals. The delay in implementation of this rule has generated a mixed reaction from the export industry.