From AFOA General Counsel, Olsson Frank Weeda:

Our team is closely monitoring ongoing challenges to the IEEPA‑based tariffs and has been advising importers on how best to preserve potential refund rights.  Please note that this client memorandum provides a high‑level overview of the principal options available and is for informational purposes only and is not individualized legal advice, as each importer’s situation must be evaluated on its own facts and merits.

We will continue to monitor closely and will report all significant developments to you. In the interim, please do not hesitate to reach out to us with questions or requests for additional information.