> As sibling says, the Court very definitely did not order them to refund anything.
> You may see other judges rule that the refunds don't have to be paid, for any of several reasons.
I think the government might have a bit of an uphill battle given arguments they have previously made to courts. For example, consider this decision from the US Court of International Trade from 2025-12 [0]:
> However, as the Government notes in its response to Plaintiffs’ motion for a preliminary injunction here, it “[has] made very clear—both in this case and in related cases—that [it] will not object to the [c]ourt ordering reliquidation of plaintiffs’ entries subject to the challenged IEEPA duties if such duties are found to be unlawful.”
>
> Judicial estoppel would prevent the Government from taking an inconsistent approach after a final result in V.O.S. [] The Government has emphasized this point itself, citing to Sumecht NA, Inc. v. United States, which holds that “the Government would be judicially estopped from taking a contrary position” regarding a prior representation involving the availability of relief in the form of reliquidation. [] Having convinced this court to accept that importers who paid IEEPA tariffs will be able to receive refunds after reliquidation, and having benefited from the court’s subsequent conclusion that importers will not experience irreparable harm as a consequence of liquidation, the Government cannot later “assume a contrary position” to argue that refunds are not available after liquidation.
>
> Additionally, the panel in In re Section 301 Cases unanimously agreed—as we do
now—that the USCIT has “the explicit power to order reliquidation and refunds where the government has unlawfully exacted duties.” [] The Government acknowledges that “a decision [to the contrary] would be inconsistent with years of [the court’s] precedent.”
Obviously all this doesn't prevent the government from appealing anyways, but they'll need to get creative to get around their previous representations.
[0]: https://www.cit.uscourts.gov/sites/cit/files/25-154.pdf