IEEPA Tariff Timeline
Key dates in the IEEPA tariff saga — from imposition to Supreme Court ruling to CAPE refund filing.
IEEPA tariffs begin
Executive orders impose 25% IEEPA tariffs on Canada and Mexico, and an initial rate on China, effective February 4, 2025. The administration cites border security, fentanyl, and trade imbalances as justification.
"Liberation Day" reciprocal tariffs
A broad executive order imposes country-specific reciprocal tariffs on more than 80 trading partners. Rates range from 10% (baseline) to 46% (Vietnam). The administration calls this "Liberation Day."
Legal challenges mount
Multiple importers, trade associations, and state attorneys general file lawsuits in the U.S. Court of International Trade. The CIT issues a preliminary injunction blocking some duty collections pending full merits review.
CIT rules tariffs unlawful
The U.S. Court of International Trade, after full briefing and argument, rules that IEEPA does not authorize open-ended tariffs. The government appeals to the Federal Circuit, which affirms. The government petitions the Supreme Court.
Supreme Court hears argument
The Supreme Court hears oral argument in V.O.S. Selections Inc. v. United States. The case attracts hundreds of amicus briefs. Observers note Chief Justice Roberts's questioning indicates skepticism of the government's position.
SCOTUS rules 6-3 — IEEPA tariffs struck down
The Supreme Court issues its opinion in V.O.S. Selections. Chief Justice Roberts writes for a 6-3 majority applying the major questions doctrine. All IEEPA reciprocal tariffs are declared unlawful. CBP immediately stops assessing IEEPA duties.
Section 122 tariffs take effect
The administration invokes Section 122 of the Trade Act of 1974 to impose a 10% universal tariff as a balance-of-payments measure. This is a distinct legal authority from IEEPA.
24 states challenge Section 122
A coalition of 24 state attorneys general files suit in the CIT challenging Section 122 tariffs as procedurally and constitutionally deficient. A preliminary injunction motion is filed simultaneously.
CBP outlines CAPE process
CBP publishes initial guidance on the CAPE refund process, announcing the planned April launch date, CSV format requirements, and ACE prerequisites.
CAPE portal launches
CBP opens the CAPE portal for IEEPA refund claim submissions. The portal experiences some technical issues in the first hours but is stable by midday. First claims are submitted.
Section 122 expires (est.)
Section 122 tariffs are limited to 150 days by statute. Absent congressional reauthorization, the tariffs expire around July 24, 2026. The Section 122 litigation may resolve before or after this date.
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