Customs Liquidation Explained:

What Importers Need to Know for IEEPA Refunds

Understanding how CBP liquidates entries is essential to knowing which refund path is available to you and how much time you have left to act. Liquidation is the formal process by which CBP closes the accounting on an import entry, locks in the final duty amount, and starts the clock on your protest window. This guide walks through each stage of the standard liquidation timeline from the original import date through the liquidation date, the 80-day CAPE filing window, the 180-day protest window, and final liquidation, with plain-language explanations of what each stage means for your IEEPA refund options. CAPE Phase 1 launched April 20, 2026, and Phase 2 launched June 29, 2026. The guide also explains how your entry’s position in the timeline determines which action you should take right now.

Step by step

Quick reference

Stage	Timing	What you can do	IEEPA refund path
Import Day 0	Goods released by CBP. Cargo release filed within 15 calendar days of arrival.	All deadlines start from this date. Each shipment has its own Day 0.	Shipments released February 4, 2025 through February 24, 2026 are potentially eligible for IEEPA refunds.
Entry Summary Day 10	10 working days after cargo release.	File CBP Form 7501 and pay estimated duties. IEEPA charges appear here under HTS 9903.01.xx and 9903.02.xx.	Document every IEEPA duty line with the entry number, amount paid, and country. This is the data you will upload as a CSV file through the CAPE tab in ACE.
PSC Window Days 1 to 300	File by Day 300 from entry date or 15 days before scheduled liquidation, whichever comes first.	Post Summary Corrections are explicitly prohibited by CBP for IEEPA refund requests. PSCs may still be filed on these entries for non-IEEPA purposes such as correcting classification issues unrelated to IEEPA duties.	CAPE is the only authorized path for IEEPA refunds. CAPE Phase 1 launched April 20, 2026 and Phase 2 launched June 29, 2026. File your CAPE Declaration through the CAPE tab under More in your ACE portal.
Liquidation Around Day 314	Typically around 314 days from import. Extendable in one-year increments up to 3 years.	PSC window closes. CBP finalizes duties. Overpayment triggers a refund plus interest.	CAPE is live. File your CAPE Declaration now. For unliquidated standard entries, refunds are generally expected within 60 to 90 days of CAPE Declaration acceptance. Entries within 80 days of liquidation can also be included and CBP will reliquidate the next business day.
Protest Window 180 days after liquidation	180 days from the liquidation date. CBP also has its own 90-day window to reliquidate on its own initiative.	File a formal Protest (CBP Form 19) challenging the liquidation decision. Note: entries with an open protest cannot be submitted on a CAPE Declaration.	Check your 80-day CAPE window first. Entries within 80 days of liquidation should go on a CAPE Declaration rather than a protest. For entries between 80 and 180 days past liquidation, a protest is available. Consult your broker or trade attorney before filing.
Final Liquidation Day 494 (if no protest filed)	180 days after liquidation with no protest filed.	The legal situation for finally liquidated entries is currently contested. In May 2026, CBP stated it lacks authority to refund these entries without importer-specific court orders. The judge rejected that position and the government appealed on June 2, 2026. Phase 3 of CAPE is expected by end of July 2026 but CBP has not confirmed it will cover finally liquidated entries.	Do not assume your options are exhausted. Consult a licensed trade attorney. CIT litigation remains available no earlier than February 3, 2027 for fentanyl tariffs and April 6, 2027 for reciprocal tariffs.

Sources: Declaration of Brandon Lord, CIT Case No. 26-01259, Document 39 (March 12, 2026) and Document 51 (March 31, 2026). Order, Atmus Filtration, Inc. v. United States, CIT Case No. 26-01259, Documents 49 and 50 (March 20 and March 27, 2026). CBP Trade User Information Notice CAPE Phase 1, Publication No. 1009-1119 (April 8, 2026). CBP CSMS No. 68340863 (April 13, 2026). CBP CSMS No. 69035485 (June 23, 2026). CBP CSMS No. 69066837 (June 2026). BDO Customs and International Trade Services (May 26, 2026). For informational purposes only. Not legal or financial advice. Contact our team directly for guidance specific to your entries.