CBP to halt IEEPA tariff collections at 12:01 a.m. Feb. 24, leaving refund questions unresolved

U.S. Customs and Border Protection told shippers it will deactivate all tariff codes tied to President Trump’s IEEPA orders and stop collecting those duties at 12:01 a.m. EST on Tuesday, Feb. 24, more than three days after the Supreme Court declared the emergency tariffs unlawful. The agency sent the notice through its Cargo Systems Messaging Service to trading partners but offered no explanation for the delay in halting collections at ports of entry and gave no information on whether importers will be reimbursed.

The Supreme Court’s decision invalidated tariffs imposed under the International Emergency Economic Powers Act, the legal vehicle used last year to announce sweeping levies. The administration announced a new 15 percent global tariff under a different legal authority to replace the struck-down measures; that replacement is scheduled to take effect alongside the code deactivation and may be temporary under separate statutory powers.

The financial stakes are substantial. Economists at the Penn-Wharton Budget Model estimate more than $175 billion in U.S. Treasury revenue generated by the IEEPA tariffs could be subject to potential refunds, and that IEEPA-based collections were producing more than $500 million per day in gross revenue. For importers and customs brokers, the absence of immediate administrative guidance leaves open whether entries made after the court’s ruling will be administratively adjusted, whether importers must file protests or claims, and who will bear the administrative burden and cost of pursuing refunds.

CBP acknowledged the trade community’s need for further detail and said, “CBP will provide additional guidance to the trade community through CSMS messages as appropriate,” but offered no timeline or mechanism for reimbursement. The agency reiterated that the halt applies only to tariffs imposed under IEEPA and does not affect other Trump-era levies invoked under Section 232 or Section 301.

The gap between the court’s ruling and CBP’s operational change has immediate implications for hospitals, clinics, community health providers and low-income families that rely on imported medical supplies, pharmaceuticals and equipment. While the specific Harmonized Tariff Schedule codes affected have not been publicly enumerated, even temporary tariff measures can increase procurement costs for health systems and manufacturers, driving higher prices for essential goods and widening inequities in access to care. Health providers operating on thin margins and community-based organizations serving vulnerable populations face heightened risk if import-related costs are passed through to patients or absorbed through service cuts.

Trade lawyers and industry groups are expected to press for swift administrative instructions, including whether refunds will be automatic, processed through customs protests, or require separate Treasury action. The lack of clear procedures risks clogging customs operations and imposing legal costs on smaller importers least able to pursue complex refunds, exacerbating market concentration and economic inequality.

The immediate priorities are straightforward: CBP and Treasury must publish the CSMS texts and a step-by-step refund process; the White House should release the legal authority and duration for the replacement tariff; and regulators should identify which product categories are affected so hospitals and community providers can plan procurement and budgets. Absent prompt clarity, the legal and economic whiplash from the court decision and the administration’s replacement tariffs will ripple through supply chains and into communities that can least afford the uncertainty.