Post-Summary Correction (PSC) for IEEPA Tariffs: The Fastest Path to a Refund

If any of your IEEPA entries are still unliquidated, you’re sitting on the fastest recovery path available. A Post-Summary Correction (PSC) lets your customs broker amend the entry summary to remove IEEPA tariff codes — and CBP processes the correction before liquidation happens. No protest. No court filing. No 18-month CAPE queue. Just a direct correction to an entry that hasn’t been finalized yet, resulting in a refund of the overpaid duties.

The catch? Entries don’t stay unliquidated forever. The typical liquidation cycle is approximately 314 days from the entry date. That means IEEPA entries filed in the first half of 2025 have already liquidated or are liquidating right now. Entries filed in mid-to-late 2025 and early 2026 likely still have a PSC window open. But that window is closing, entry by entry, every single day.

If PSC is available for even a portion of your entries, it should be your first priority. Here’s everything you need to know.

What Is a Post-Summary Correction?

A Post-Summary Correction is a mechanism under 19 CFR 173.4 that allows an importer (through their customs broker) to correct an entry summary after it’s been filed but before it’s been liquidated. Think of it as amending a tax return before the IRS processes it. The correction replaces the original data with updated data, and CBP processes the entry based on the corrected version.

PSCs have been part of customs law for decades. Brokers use them routinely to fix errors in entry summaries — wrong HTS codes, incorrect values, missing information. What’s new is using PSC at scale to remove IEEPA tariff codes from thousands of entries, based on the Supreme Court ruling that invalidated the legal basis for those tariffs.

The legal basis is straightforward. The Supreme Court ruled that IEEPA tariffs were unconstitutional. The CIT’s March 4 order directed CBP to process refunds on entries where liquidation is not yet final. For unliquidated entries, the cleanest path to compliance with that order is a PSC that removes the tariff codes that should never have been there.

Who Files a PSC?

Your customs broker files the PSC on your behalf through CBP’s ACE (Automated Commercial Environment) system. You don’t file it yourself, and you don’t need an attorney. The broker needs:

1. A valid Power of Attorney (POA) from the importer of record. If your broker already handles your entries, they almost certainly have this on file. If not, you’ll need to execute one before they can file.

2. Access to the original entry data. The broker needs the entry number, the original HTS codes, the original duty amounts, and the corrected versions (with IEEPA codes removed).

3. The corrected entry summary data. This is the updated version of the entry summary with HTS headings 9903.01 and 9903.02 removed, and the corresponding duty amounts reduced.

If you’ve changed customs brokers since the original entries were filed, your new broker can still file the PSC — but they’ll need to obtain the original entry data from the prior broker or from your ACE account. This handoff can add time, so if you’re in this situation, start the process immediately.

Which Entries Qualify for PSC?

PSC is available only for unliquidated entries. An entry is unliquidated if CBP has not yet finalized the duty determination. Here’s how to figure out which of your entries qualify:

Check Liquidation Status

Pull an ES-003 report from the ACE portal (or ask your broker to pull it). This report includes the liquidation status of each entry. You’re looking for entries marked as “unliquidated” or “open” that also include IEEPA duty codes under HTS headings 9903.01 or 9903.02.

Estimate the Window

The typical liquidation cycle is approximately 314 days from the entry date. IEEPA tariffs took effect on February 4, 2025. Here’s the math:

These are estimates. Actual liquidation dates vary based on CBP processing workload, port of entry, and other factors. The only way to know for certain is to check the actual liquidation status in ACE.

What About Entries Being Held?

CBP has indicated that some IEEPA entries may be held in “suspended liquidation” status pending the resolution of refund processing. If your entries are in suspended status, they’re still unliquidated and PSC-eligible. However, CBP’s position on suspended entries has been evolving, so confirm with your broker before assuming this applies to your entries.

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How to File a PSC: Step by Step

Here’s the process from start to finish:

Step 1: Identify Affected Entries

Pull your entry data and create a list of all unliquidated entries with IEEPA duty codes. For each entry, note:

• Entry number
• Entry date
• Port of entry
• HTS codes including 9903.01.xx or 9903.02.xx designations
• IEEPA duty amount paid
• Current liquidation status

Your Impact Assessment will generate this list automatically, with recovery path recommendations for each entry.

Step 2: Prepare the Corrected Entry Summary

Your customs broker prepares the corrected entry summary data. The correction involves:

• Removing IEEPA HTS codes (9903.01 and 9903.02 headings)
• Recalculating total duties without the IEEPA surcharge
• Retaining all other duty assessments (regular tariffs, Section 301, antidumping/countervailing duties, etc.)
• Documenting the legal basis for the correction (Supreme Court ruling in Learning Resources, Inc. v. Trump)

The corrected summary should result in a lower total duty amount equal to the original amount minus the IEEPA component. If the IEEPA tariff was 25% on a $100,000 shipment, the correction removes $25,000 from the duty total. The remaining duties (if any) stay in place.

Step 3: Submit Through ACE

Your broker submits the PSC through the ACE system electronically. The submission includes:

• The original entry number
• The corrected entry summary data
• A reason code indicating the basis for the correction
• Supporting documentation (reference to the Supreme Court ruling)

CBP’s ACE system validates the submission and either accepts it for processing or rejects it with an error code. Common rejection reasons include: entry has already liquidated, data format errors, or incomplete documentation.

Step 4: CBP Review and Processing

Once accepted, CBP reviews the PSC and processes the correction. For a standard PSC, this typically takes days to a few weeks. Given the volume of IEEPA PSCs being filed across the system, processing times may be longer than usual — but PSC is still significantly faster than the protest path (18-36 months) or CAPE queue processing.

Step 5: Refund Issuance

After processing the correction, CBP recalculates the duty and issues a refund for the difference to the importer of record. The refund includes statutory interest under 19 U.S.C. Section 1505(c), calculated from the date the duties were deposited to the date of the refund.

What Fields Change on the Corrected Entry?

For brokers and importers who want the technical details, here’s exactly what changes on the entry summary:

Removed:

• HTS classification lines for 9903.01.xx and 9903.02.xx
• Associated duty amounts for IEEPA tariff lines
• Any ad valorem calculation tied to IEEPA rates

Unchanged:

• Original HTS classifications for the underlying products
• Regular duty rates (Column 1, Column 2)
• Section 301 tariff lines (if applicable)
• Antidumping/countervailing duties (if applicable)
• Merchandise Processing Fee (MPF)
• Harbor Maintenance Fee (HMF)
• Entry date, port, IOR, and all other header information

Recalculated:

• Total duty, tax, and fee amount (reduced by the IEEPA component)
• Any line-item totals that included IEEPA surcharges

The net effect is a cleaner entry that reflects what duties should have been assessed if IEEPA tariffs had never existed.

PSC Limitations: What It Can’t Do

PSC is powerful but not universal. Here’s what it can’t handle:

Already Liquidated Entries

Once an entry liquidates, PSC is no longer available. The entry has been finalized by CBP, and the only way to challenge it is through a formal protest under 19 U.S.C. Section 1514 (if within the 180-day window) or CIT litigation (if outside the window). If you discover that entries you expected to be unliquidated have already liquidated, you need to shift to the protest path immediately.

Entries With Other Unresolved Issues

If an entry has pending CBP actions — a compliance review, a request for information, a penalty case — filing a PSC may not resolve the IEEPA component independently. Your broker should check for any open CBP actions on the entry before filing.

Large Volumes May Cause Processing Delays

CBP wasn’t designed to handle thousands of PSCs simultaneously across hundreds of thousands of importers. While individual PSC processing is fast, system-wide volume may create backlogs. This is one reason early filing matters — importers who file PSCs now, before the wave peaks, will likely see faster processing.

No Recovery for Entries You Didn’t File

PSC corrects entries already on file. If your company was the consignee but not the importer of record, PSC filed by a third-party IOR won’t automatically redirect the refund to you. You’d need a separate arrangement with the IOR.

PSC vs. Other Recovery Paths

How does PSC compare to the other options? Here’s the side-by-side:

The four recovery paths guide provides a detailed comparison, but the takeaway is clear: if PSC is available, use it first. It’s faster, cheaper, and simpler than every other option.

What Happens If the Entry Liquidates While You’re Preparing?

This is the nightmare scenario — and it happens. You identify an unliquidated entry, start preparing the PSC, and before your broker files it, CBP liquidates the entry. Now PSC is off the table.

The good news: you haven’t lost your refund. You’ve lost the fastest path to it. Once the entry liquidates, you shift to the protest path. You have 180 days from the liquidation date to file a formal protest. The refund amount is the same — it just takes longer to process.

The lesson: don’t sit on unliquidated entries. If your ES-003 report shows entries that are approaching the estimated liquidation date, prioritize those for immediate PSC filing. Entries filed in mid-2025 are liquidating right now. Every day of delay increases the risk that an entry slips from the fast PSC path to the slow protest path.

Practical Tips for a Smooth PSC Filing

Based on the thousands of IEEPA entries we’ve analyzed, here are the practical tips that make PSC filings go smoothly:

1. Batch your entries by port. CBP processes PSCs at the port level. Grouping your submissions by port of entry can improve processing efficiency and reduce the chance of routing errors.

2. Verify HTS codes before filing. Make sure you’re only removing IEEPA-specific codes (9903.01 and 9903.02 headings). Don’t accidentally remove Section 301 or other valid tariff codes. A coding error that removes the wrong line items can trigger a CBP compliance review.

3. Keep copies of everything. Document the original entry, the corrected entry, and the PSC submission confirmation. If there’s a discrepancy later, you’ll need this paper trail.

4. Monitor processing. After filing, check the ACE system periodically to confirm that the PSC has been processed and the refund is being issued. Don’t assume that filed equals processed.

5. Coordinate with your broker. If you use multiple brokers across different ports, make sure each broker is aware of the PSC strategy and has the necessary data and POA to file. Centralize the effort through your Impact Assessment to avoid gaps.

6. File before CAPE launches. CBP’s CAPE system is designed to process IEEPA refunds at scale, but it’s built for claims where the normal PSC/protest mechanisms don’t apply. If you can resolve your unliquidated entries through PSC before CAPE launches, you avoid the queue entirely.

Real-World PSC Scenarios

To make this concrete, here are three common scenarios importers face and how PSC applies:

Scenario 1: Single broker, clean data. A mid-size apparel importer filed 200 entries from China between May and December 2025, all through the same customs broker. About 120 entries are still unliquidated. The broker pulls the ES-003, identifies the IEEPA lines, prepares corrected summaries, and files PSCs in batches of 20-30 entries per port. Total IEEPA duties: $1.2 million. Expected processing time: 2-4 weeks per batch. No complications.

Scenario 2: Multiple brokers, mixed status. A consumer electronics importer used three different brokers across five ports. They have 500 entries, of which roughly 180 are still unliquidated. Each broker needs to file PSCs for their respective entries. The importer’s Impact Assessment identifies which entries belong to which broker and port, enabling coordinated filing. Some entries have already liquidated and will shift to the protest path. Total IEEPA duties across unliquidated entries: $3.4 million.

Scenario 3: Approaching liquidation dates. An auto parts importer has 80 entries from April-May 2025 that are estimated to liquidate within the next 30-60 days. These are the highest-priority PSC filings — if they liquidate before the PSC is filed, the importer loses the fast path and must file protests instead. The broker fast-tracks these entries while preparing PSCs for the remaining 150 entries that have more time. This kind of deadline-driven prioritization is exactly what the Impact Assessment is designed to identify.

The Bottom Line

PSC is the lowest-friction, fastest-resolution recovery path for IEEPA tariffs. If you have unliquidated entries, this should be the first phone call you make — to your customs broker, to start preparing the filings. The window is real and it’s closing as entries liquidate on their regular cycle.

For importers with a mix of unliquidated and liquidated entries, the smart approach is to file PSCs immediately on everything that qualifies, then shift to protests and CAPE filings for entries that have already liquidated. The government filing vs. immediate capital analysis can help you evaluate whether the CAPE queue makes sense for your liquidated entries or whether claim assignment is a better use of your time and capital.

An Impact Assessment identifies every unliquidated entry in your portfolio, estimates the refund amount, and maps the PSC filing plan. It’s free, confidential, and typically delivered within 5-10 business days.