For every liquidated import entry, federal law provides a 180-day window to file a formal protest with CBP under 19 U.S.C. Section 1514. Once that window closes, the entry is considered final and conclusive. The only remaining path to challenge assessed duties is litigation at the Court of International Trade, which is slower, more expensive, and less certain.
With the earliest IEEPA entries now reaching and passing their liquidation dates, this window has become the single most time-sensitive element of the tariff recovery process.
How the timeline works
The article's timing logic is sequential: entry filing leads to liquidation, liquidation starts the protest clock, and missing that clock pushes the claim into the CIT-only lane.
Import entries typically liquidate approximately 314 days after the entry date. This is when CBP finalizes the duty assessment and the entry becomes part of the official record. Understanding how liquidation status affects your options is essential before deciding on a recovery path.
The first IEEPA tariffs took effect on February 4, 2025. Entries filed on or shortly after that date began liquidating around December 2025. The 180-day protest window for those earliest liquidations will expire approximately in June 2026. This means the first batch of protest deadlines is approaching rapidly, and the number decreases by one every day.
For a complete chronological view of how these deadlines developed, see our IEEPA tariff refund timeline.
Why this matters even with the CIT order
The March 4 CIT order directed CBP to reliquidate entries where liquidation is not yet final. “Not final” means the 180-day protest period has not expired. This is why filing a protest — even a protective one — is critical.
A protested entry remains “not final” and is therefore covered by the CIT order. An unprotested entry that passes the 180-day mark becomes final and falls outside the scope of the universal refund order. Filing a protest is not just about challenging the duty assessment. It is about keeping your entries alive within the legal framework that will deliver refunds.
How to calculate your deadline
Each entry has its own deadline based on its specific liquidation date. To determine your timeline, you need to know the liquidation date of each affected entry. This information is available in CBP’s ACE portal under the entry summary reports.
Your customs broker can pull this data. Request an ES-003 report covering all entries with HTS codes beginning with 9903.01 and 9903.02, and specifically ask for liquidation dates to be included. Our documentation guide details the exact fields and reports required. Once you have the liquidation dates, add 180 days to each one — that is your protest deadline for that entry.
What a protective protest looks like
A formal protest under 19 U.S.C. Section 1514 is filed through CBP’s ACE portal by your customs broker or by you as the importer of record. The protest identifies the specific entry, states the basis for the challenge (in this case, that IEEPA tariffs have been ruled unconstitutional in Learning Resources, Inc. v. Trump), and requests reliquidation without the IEEPA duty assessment.
CBP has up to two years to review and decide on a protest. However, importers can request accelerated disposition. If CBP does not respond within 30 days of the request, the protest is deemed denied, which allows the importer to escalate to the Court of International Trade without waiting for CBP to act.
What happens if you miss the window
If the 180-day protest period expires without a filing, the entry becomes finally liquidated. The CIT’s universal refund order does not cover finally liquidated entries. The only remaining option is to file a separate action at the CIT under 28 U.S.C. Section 1581(i), which has a two-year statute of limitations from the date of the contested action.
This path is available but significantly more complex, expensive, and time-consuming than the administrative protest route. Our guide on CIT litigation for IEEPA tariff recovery explains the process and costs in detail. For importers with large IEEPA exposure, missing the protest window could mean the difference between recovering funds in months versus years — or not at all. Our four recovery paths comparison explains how CIT litigation differs from the other available options.
Importers with China-specific exposure
Importers who concentrated shipments from China during the IEEPA period may face the earliest and largest deadlines, given that China IEEPA rates reached as high as 145% at peak. The China IEEPA tariff refund guide provides specific rate schedules and deadline analysis for China-origin entries.
The immediate capital alternative
For importers who face tight protest deadlines and prefer certainty over government timelines, claim assignment through institutional buyers provides non-recourse capital within 14-21 business days. This eliminates dependence on CBP processing timelines entirely.
The bottom line
Identify your liquidation dates. Calculate your 180-day deadlines. File protective protests on every liquidated entry that is still within the window. For a comprehensive walkthrough of the entire refund process, see our complete guide to IEEPA tariff refunds. Do not wait for CBP to finalize the CAPE portal — read our CAPE system explainer to understand why. Do not wait for further court guidance. The protest preserves your rights under every scenario — whether CBP issues refunds automatically, whether the CIT order is appealed, or whether the process takes longer than anyone expects.
Request a confidential Impact Assessment to identify which of your entries are approaching deadline and which recovery path applies to each one. Customs brokers who advise multiple importers on protest filings may also benefit from the partner referral program, which provides assessment support at no cost to the referring broker.
