IEEPA Tariffs: A Possible Roadmap for APPA Members as the Clock Ticks Down

In the closing segment of APPA’s latest Trade Talks update, customs expert Rebecca Rizutti delivered a clear, practical message to importers: time is no longer abstract when it comes to IEEPA and reciprocal tariffs. The liquidation clock is running, and APPA members need to decide now, how they want to position themselves for potential refunds. 

Know Your Dates: 270 Days and the 314-Day “Red Zone”

Rebecca reminded members that every tariff-impacted entry has its own countdown. Roughly:

• Around 270 days after the import date, you should be actively deciding what you want to do with that entry.
• Around Two Strategic Choices: Let It Ride or Try to Stop the Cloc, you are in what she called the “red zone”, very close to liquidation, with limited time left to act.

For many early IEEPA entries, those milestones are already here or rapidly approaching. Whether companies are ready or not, “we are all on this path and we’re all moving forward,” she emphasized.

If you want to protect your ability to seek a refund later, you cannot let those dates creep up without a plan.

Two Strategic Choices: Let It Ride or Try to Stop the Clock

Rebecca helped APPA create a decision tree in which she laid out two primary strategies, each with trade-offs. Please note that the content of the "IEEPA decision tree" or this blog is for informational purposes only, and you should not act on the basis of this content without seeking legal or other professional advice.

Here are some steps you may want to consider discussing with your counsel:

1. Try to stop liquidation (pause the clock)
   • Step 1: Request a liquidation extension from CBP, through your broker, internal trade team, or outside counsel.
   • If CBP grants the extension, the entry remains unliquidated, and you can wait to see how the Supreme Court rules on IEEPA tariffs. If the tariffs are struck down, you can file a Post-Summary Correction (PSC) and seek a refund administratively.
   • If CBP denies the extension and the entry is headed toward liquidation, you can go further and file a complaint with the Court of International Trade (CIT), asking the court to effectively suspend liquidation and preserve your rights while the IEEPA case is decided. Please note that the CIT has recently requested that companies await the Supreme Court Decision before they will review submissions.
2. Let the entry liquidate and rely on protests
   • Allow liquidation to proceed.
   • Within 180 days of liquidation, file a protest arguing the IEEPA tariffs are unlawful.
   • If CBP grants the protest, you receive a refund; if CBP denies, you can again escalate to the CIT.

Rebecca stressed that many importers are choosing the more proactive “stop the clock” path, filing CIT complaints now to suspend liquidation and avoid the risk that liquidated entries might later be excluded from any refund regime the courts or government put in place. 

The Decision Tree

The IEPPA Decision Tree is designed to give you some general information and give you the steps you may want to consider discussing with your own counsel to help you move quicker and more efficiently. As an example, you could:

• Start by requesting an extension from CBP.
• Depending on whether it is granted or denied, follow the branch that leads to either waiting with unliquidated entries, filing protests, or going to the CIT to preserve refund rights.

Rebecca’s bottom line: whatever path you choose, you must first have clean reporting. Work with your broker or customs partner now to pull a list of all entries hit by IEEPA/reciprocal tariffs, along with their entry and projected liquidation dates. With that in hand, you can move quickly, whether that means filing extensions, preparing protests, or joining CIT actions.

IEEPA may rise or fall at the Supreme Court, and 301/232 tariffs are likely to remain in some form. But APPA members who understand their timelines and use this decision framework will be far better positioned whatever the courts decide.

Join us for our next office hours on January 21, 2026, from 3 PM to 4 PM ET.

Disclaimer: APPA does not make any representations about the completeness, suitability, or adequacy of the information provided in this blog.  Any information provided are intended for general informational purposes only, they do not constitute a recommendation or solicitation to do or omit to do any action and should not be interpreted as legal, regulatory, or compliance advice. You should seek independent advice from qualified professionals before acting on any information provided and/or to evaluate specific regulatory obligations and operational decisions.