Customs Liquidation Explained:

What Importers Need to Know for IEEPA Refunds

Understanding how CBP liquidates entries is essential to knowing which refund path may be available and how much time you have to act. Liquidation is the formal process by which CBP closes the accounting on an import entry, determines the final duty amount, and starts the 180-day protest period.

This guide walks through each stage of the standard liquidation timeline, from the original import date through liquidation, the 80-day CAPE filing window, the 180-day protest window, and final liquidation. It also explains what each stage means for your IEEPA refund options.

CAPE Phase 1 launched April 20, 2026, Phase 2 launched June 29, 2026, and Phase 3 for qualifying finally liquidated entries filed by CIT plaintiffs is scheduled to launch October 6, 2026. Your entry’s actual liquidation status and dates should always be verified in ACE or with your customs broker before taking action.

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. As of September 11, 2026, 27.2 million entries have been accepted for IEEPA duty removal and $122 billion has been sent to Treasury.
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.	Phase 3 launches October 6, 2026 for CIT plaintiffs who submitted a valid IOR number to CBP by July 30, 2026. Plaintiffs who submitted after July 30 will receive separate CBP instructions. Importers who have not filed a CIT lawsuit have no confirmed Phase 3 mechanism.	Consult a licensed trade attorney about whether filing a CIT action is appropriate. CIT litigation remains available no earlier than February 3, 2027 for fentanyl tariffs and April 6, 2027 for reciprocal tariffs. Do not assume your options are exhausted but act promptly.

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). Declaration of Brandon Lord, Freestyle World, Inc. v. United States, Court No. 26-01088, Document 38 (August 25, 2026). Declaration of Brandon Lord, Freestyle World, Inc. v. United States, Court No. 26-01088, Document 50 (September 15, 2026). For informational purposes only. Not legal or financial advice. Contact our team directly for guidance specific to your entries.