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 PSC window, the expected liquidation date, the 180-day protest window, and final liquidation, with plain-language explanations of what each stage means for your IEEPA refund options. It also shows the current status of CBP’s CAPE refund system and 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 to the CAPE Claim Portal.
PSC Window Days 1 to 300 or 15 days before liquidation	File by Day 300 from entry date or 15 days before scheduled liquidation, whichever comes first.	Post Summary Correction: amend the entry in ACE to remove IEEPA tariff lines. Administrative, not legal. Filed by your customs broker in ACE.	Best option for unliquidated entries excluded from CAPE Phase 1. For standard entries, wait for CAPE. For complex-status entries, consult your broker about a protective PSC.
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.	The CAPE system will handle refunds here. As of March 30, 2026: Claim Portal 85% complete, Mass Processing 60%, Review and Liquidation 80%, Refund component 75%.
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.	On March 27, 2026, the court ordered CBP to reliquidate all IEEPA entries including liquidated ones. Consult your customs broker or trade attorney before filing a protest, as the court order may cover your entry without one. Filing a protest still preserves your CIT rights if needed.
Final Liquidation Day 494 (if no protest filed)	180 days after liquidation with no protest filed. Permanent and irrevocable.	Court order covers these but Phase 1 of CAPE will not process them. CBP confirmed March 31, 2026 that finally liquidated entries are deferred to a subsequent CAPE phase.	Consult a trade attorney before filing a protest or CIT action. The court order may cover your entries without further action. CIT deadline remains February 3, 2027 for fentanyl tariffs and April 6, 2027 for reciprocal tariffs.