ICON EV LLC v. United States

United States Court of International Trade·Decided April 24, 2026·No. 26-02759·Published

Opinion

Slip Op. 26-

UNITED STATES COURT OF INTERNATIONAL TRADE

ICON EV LLC, Plaintiff,

v.

Before: Jane A. Restani, Judge UNITED STATES; U.S. CUSTOMS AND Court No. 26-02759

BORDER PROTECTION; and ERIC CHOY, in his official capacity as Executive Director, Trade PUBLIC VERSION

Remedy Law Enforcement Directorate, Office of Trade, U.S. Customs and Border Protection,

Defendants.

OPINION

[Plaintiff’s motion for a temporary restraining order and preliminary injunction is granted.] Luke Mathers, Sandler, Travis & Rosenberg, P.A., of New York, NY, argued for the plaintiff ICON EV LLC. With him on the brief were Deborah Beth Stern and Sarah Suzanne Sprinkle. Adam Angelo Vischio, Trial Attorney, International Trade Field Office, Civil Division, U.S. Department of Justice, of New York, NY, argued for the defendant. With him on the brief were Douglas Glenn Edelschick, Senior Trial Counsel, and Edward Francis Kenney. Of counsel were Nicolas Alexander Morales, Office of Chief Counsel, U.S. Customs and Border Protection and Tamari J. Lagvilava, Senior Attorney, of Washington, DC.

Dated: April 24, 2026

Restani, Judge: Before the court is ICON EV LLC’s (“ICON”) motion for a temporary

restraining order and preliminary injunction, Pl.’s Mot. for TRO and Prelim. Inj., ECF No. 5 (Apr. 13, 2026) (“Mot.”), and the government’s opposition thereto and motion to dismiss for lack of subject matter jurisdiction. Defs.’ Mot. to Dismiss and Opp’n to Pl.’s Mot. for TRO & Prelim. Inj., ECF No. 24 (Apr. 17, 2026) (“Opp.”). ICON seeks to enjoin the imposition of certain interim

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measures under the Enforce and Protect Act (“EAPA”) pending the United States Department of Customs and Border Protection’s (“Customs”) EAPA investigation. See Mot. at 2. Because the court likely has subject matter jurisdiction and because the preliminary injunction factors weigh in ICON’s favor, the court grants ICON’s motion for a preliminary injunction. On April 23, the court held a preliminary injunction hearing where it granted ICON’s motion for a TRO. See Order, ECF No. 37 (Apr. 23, 2026).

BACKGROUND 1

On April 13, 2026, ICON filed its complaint asserting that Customs’ imposition of interim measures without prior notice or a meaningful opportunity to be heard violated its Fifth Amendment Due Process rights. See Compl., ECF No. 1 (Apr. 13, 2026). Alongside its complaint, ICON filed its motion for a temporary restraining order and preliminary injunction enjoining enforcement of the interim measures “during the pendency of Customs’ EAPA investigation.”2 Mot. at 2. The government filed its opposition to ICON’s motion on April 17, 2026, see Opp’n, and ICON filed its reply on April 20, 2026. See Pl.’s Resp. in Opp. to Def.’s Mot. to Dismiss and Reply in Supp. of its Mot. for a TRO and Prelim. Inj., ECF No. 31 (Apr. 20, 2026) (“Reply”).

I. The EAPA Generally At issue in this case are certain interim measures imposed on ICON pursuant to the EAPA.

The EAPA was enacted to “empower the U.S. Government and its agencies with the tools to identify proactively and thwart evasion at earlier stages to improve enforcement of U.S. trade laws, including by ensuring full collection of [antidumping and countervailing] duties and, thereby,

1 The findings of fact and conclusions of law made by a court granting a preliminary injunction are not binding. Univ. of Texas v. Camenisch, 451 U.S. 390, 395 (1981). 2 ICON does not seek to enjoin the interim measures “to the extent that they merely extend or suspend liquidation.” Mot. at 2.

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preventing a loss in revenue.” Asia Wheel Co. v. United States, 762 F. Supp. 3d 1289, 1298 (CIT 2025) (quoting Diamond Tools Tech. LLC v. United States, 545 F. Supp. 3d 1324, 1351 (CIT 2021)). It mandates Customs to investigate reasonable allegations of evasion within fifteen business days and requires Customs to issue a final determination within 300 days of commencing its investigation. 3 See 19 U.S.C. § 1517(b), (c). An interested party may appeal the final determination and seek judicial review thereafter. See id. § 1517(f), (g).

Relevant here, Customs must impose interim measures within 90 days of starting its investigation if “there is a reasonable suspicion” of evasion. See 19 U.S.C § 1517(e). These interim measures include, at a minimum, suspension and extension of liquidation for unliquidated entries. Id. § 1517(e)(1)–(2). Customs may impose additional measures if “necessary to protect the revenue of the United States.” Id. § 1517(e)(3). The statute does not require Customs to notify affected parties before it imposes interim measures. But see 19 U.S.C. § 1517(c)(4) (requiring notice five business days after final determination). While the EAPA allows for judicial review of a final determination after appeal, see 19 U.S.C. § 1517(g), the statute provides no explicit basis for judicial review of interim measures. 4 II. The EAPA Investigation On August 12, 2025, the United States Department of Commerce (“Commerce”) issued antidumping and countervailing duty orders on low-speed personal transportation vehicles (“LSPTVs”) from the People’s Republic of China (“China”). See Certain Low-Speed Personal Transportation Vehicles From the People’s Republic of China: Amended Final Antidumping Duty

3 Customs may extend the time to make a determination in certain circumstances. See 19 U.S.C. § 1517(c)(1)(B). 4 Subsection 1517(g)(3) provides that nothing in subsection 1517(g) shall affect the availability of judicial review under another provision of law.

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Determination and Antidumping Duty Order; Amended Final Determination of Countervailing Duty Investigation and Countervailing Duty Order, 90 Fed. Reg. 38,759 (Dep’t Commerce Aug. 12, 2025) (the “LSPTV Orders”).

The LSPTV Orders have a precise and limited scope. They cover certain Chinese-origin LSPTVs and “subassemblies thereof, whether finished or unfinished and whether assembled or unassembled.” LSPTV Orders at 38,763. An unfinished and/or unassembled LSPTV “covers at a minimum a subassembly, also known as a ‘rolling chassis,’ which is typically comprised of, but not limited to, a frame or body” with installed suspension components and installed or installation- ready powertrain components. Id. The LSPTV Orders distinguish between Chinese-origin parts that are imported on the same bill of lading as a Chinese-origin rolling chassis—which are covered—and Chinese-origin parts that are imported on separate bills of lading—which are not covered. Id.

On October 10, 2025, and December 8, 2025, the American Personal Transportation Vehicle Manufacturers Coalition (the “Coalition”) submitted allegations that ICON 5 was evading the LSPTV Orders. 6 See Notice of Initiation of Investigation and Interim Measures - EAPA Cons. Case 8247 at 2–3, 4–6, ECF No. 24-2 (Apr. 17, 2026) (“Notice”). Specifically, the Coalition alleged that ICON was “importing LSPTVs in disassembled form by breaking down LSPTVs into

5 ICON imports certain proprietary models of electric golf carts into the United States. See Decl. of Roy Williams ¶ 2, ECF No. 13-1 (Apr. 14, 2026) (“Williams Decl.”). ICON is also the ultimate consignee of the same merchandise imported by Marxon Energy Inc. (“Marxon”) between October 8, 2025, and March 18, 2026, and is responsible for the payment of all duties owed on Marxon’s entries. Id. ¶ 3. 6 Customs had issued CF-28 Requests for Information to ICON and Marxon prior to receiving the Coalition’s allegations. See Williams Decl. ¶ 10; see also Notice of Initiation of Investigation and Interim Measures - EAPA Cons. Case 8247 at 10 n.85, ECF No. 24-2 (Apr. 17, 2026) (“Notice”). ICON responded with origin verifications for certain of its golf cart builds and provided a virtual tour of its Vietnam factory. Williams Decl. ¶ 10. As a result of these responses, Customs reverted certain ICON entries to type 01 status from type 03, i.e., those with unfair trade duties. Id.

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