Specifically, CBP indicated that Phase 2, which will cover reconciliation entries, is expected to launch on June 29, 2026. CBP further stated that Phase 3, which is intended to cover all finally liquidated entries subject to IEEPA tariffs, is expected to launch at the end of July 2026.

At the same time, CBP reiterated its opposition to a universal refund mechanism, arguing that Phase 3 should be limited to importers that have filed suit at the CIT. We therefore expect continued litigation regarding whether refunds will ultimately be available to all affected importers or only to those participating in the litigation.

Given this uncertainty, companies with outstanding IEEPA duty refunds that have not yet instructed us to file a pleading before the CIT should contact us immediately to do so.

For further information, please contact Gail Cumins at gcumins@spcblaw.com, Alli Baron at abaron@spcblaw.com or call us at 212-425-0055.

• increasing bonding requirements and requiring IORs to maintain a minimum level of tangible domestic assets, bonding, or both;
• subjecting foreign IORs to heightened requirements for formal entry;
• limiting informal entry filings to U.S.-based IORs;
• imposing a “good standing” requirement on all IORs and their affiliates; and
• increasing vetting procedures for all individuals and entities engaged in activities directly related to the importation of goods, including foreign IORs, affiliates of IORs, customs brokers, custodians of bonded merchandise, and freight forwarders.

In addition, the order directs DHS and CBP to establish enhanced import disclosure and certification requirements and to increase customs enforcement. Among other measures, the order calls for the establishment of a minimum penalty “floor” of 50%, limiting CBP’s discretion to mitigate penalties, and directs DHS to expedite and enhance the seizure and disposal of non-compliant imports

The executive order signals a significant shift toward enhanced customs enforcement and stricter importer accountability.

Accordingly, we encourage you to take this opportunity to ensure that your company is complying with all applicable import regulations, including classification, valuation, origin disclosures, marking, etc.

Now may be the ideal time to conduct an internal audit to assess your compliance.

We are at your disposal to prepare an audit plan, review your classifications, and reconfirm your valuation methodology. To discuss the best next steps for your company, please contact us.