As noted in our prior Phillips Lytle notice, Executive Order 14289 of April 29, 2025 regarding potential overlap and accumulation (“stacking”) of U.S. tariffs stated that U.S. Customs and Border Protection (CBP) would issue directions for seeking refunds on duties that had been paid inconsistent with the Order. This “stacking” guidance applied to Section 232 duties on steel, aluminum, autos and auto parts; and to certain tariffs on non-USMCA Canadian and Mexican products.
CBP issued a notice on May 16, 2025 providing information outlining the process for obtaining such refunds. Importers may now seek refunds of inappropriately “stacked” duties (as defined by the Order) by filing a Post-Summary Correction for entries as yet unliquidated; or for entries already liquidated for which the applicable protest period remains yet unexpired, filing a protest under 19 U.S.C. 1514.
The Phillips Lytle International Business Team is prepared to address any questions regarding current tariffs and import regulations.
Additional Assistance
For more information please contact James Kevin Wholey at (202) 617-2714 or jwholey@phillipslytle.com; any member of the Phillips Lytle International Business Law Team; or the Phillips Lytle attorney with whom you have a relationship.
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