The most common reason importers lose refund eligibility is missing the per-entry protest deadline.
Under 19 USC 1514(c)(3), an importer has exactly 180 days from the date of liquidation to file a protest challenging any CBP decision regarding an entry, including the assessment of duties. This statute applies directly to IEEPA tariff refund claims — if you paid IEEPA duties on a liquidated entry, your only path to recovery is filing a CBP protest within this 180-day window.
The critical point that many importers miss is that this is a per-entry deadline. There is no single "IEEPA refund deadline" that applies to all entries. Each import entry has its own liquidation date, which means each entry has its own 180-day countdown. An importer who made 200 shipments over the period IEEPA tariffs were in effect may have 200 different deadlines, potentially spread across six months or more.
The timeline for each entry follows a predictable sequence, though the exact dates vary:
For example, consider an entry made on April 15, 2025. If CBP liquidated that entry on February 23, 2026 (314 days later), the 180-day protest window runs from February 23, 2026 to August 22, 2026. Miss August 22, and the refund opportunity for that entry is gone permanently.
Now consider a second entry from the same importer, made on July 1, 2025. If that entry was liquidated on May 11, 2026, the protest deadline would be November 7, 2026 — nearly three months after the first entry's deadline. This staggered timing is why tracking every entry individually is essential.
Liquidation dates are the key data point for determining your protest deadlines. There are several ways to find them:
Warning: Some entries may be in "suspended liquidation" status, meaning CBP has not yet finalized the duty assessment. Suspended entries do not start the 180-day clock until they are liquidated, but you should still track them and file promptly once liquidation occurs.
The consequence of missing the 180-day window is absolute: you lose the right to protest that entry. There is no late-filing provision, no hardship exception, and no judicial extension available under 19 USC 1514. Courts have consistently upheld the 180-day limitation as jurisdictional, meaning even a court cannot waive it.
This strict enforcement means that importers with the earliest liquidated entries face the most urgent situation. If your first IEEPA-affected entries were liquidated in late 2025 or early 2026, some of those 180-day windows may already be approaching expiration. Every day of delay increases the risk of losing refund eligibility on your earliest entries.
The financial impact can be substantial. Consider an importer who paid $500,000 in IEEPA tariffs across 50 entries. If 10 of those entries (representing $100,000 in IEEPA duties) pass the 180-day window before protests are filed, that $100,000 is gone. There is no mechanism to recover it after the deadline passes.
If you cannot file protests for all entries simultaneously — due to documentation gathering, resource constraints, or sheer volume — you need a prioritization strategy. The optimal approach considers two factors: deadline urgency and refund value.
Sort all affected entries by their protest deadline (liquidation date + 180 days). Identify entries with deadlines in the next 30, 60, and 90 days. Entries within 30 days of their deadline should be filed immediately, even if documentation is not perfect — you can supplement a protest with additional documentation after filing, but you cannot file after the deadline.
Among entries with similar deadlines, prioritize those with the highest IEEPA duty amounts. A single $50,000 entry is worth more attention than ten $500 entries. Calculate the IEEPA duty component for each entry and rank by value within each deadline cohort.
The most effective approach assigns a priority score based on both factors. Entries with near-term deadlines and high values get filed first. Entries with distant deadlines and low values can wait. RefundAssist automates this prioritization, showing a color-coded dashboard of every entry ranked by filing urgency and refund value.
CBP allows certain efficiencies for importers filing multiple protests:
For importers with more than 20–30 entries, manual preparation becomes impractical. The documentation requirements for each entry — entry summary, commercial invoice, duty calculation, legal brief — multiply quickly. An importer with 100 entries filing manually might need 40–80 hours of preparation time.
Not all entries follow the standard liquidation timeline. CBP may suspend liquidation for various reasons, including ongoing investigations, pending court decisions, or administrative holds. Entries with suspended liquidation have not started the 180-day clock because they have not been liquidated yet.
If you have entries in suspended status, monitor them closely. Once CBP lifts the suspension and liquidates the entry, the 180-day clock begins immediately. The risk is that multiple suspended entries could be liquidated simultaneously, creating a surge of deadlines in a short period. Having your documentation and protest templates prepared in advance ensures you can file quickly when liquidation occurs.
RefundAssist was designed specifically to solve the deadline-tracking problem at scale:
Don’t wait: Use our free estimate tool to see your total potential refund and identify which entries are closest to their deadlines.
The 180-day clock starts on the date of liquidation for each individual entry, not on the date of the Supreme Court ruling or the date you paid duties. Liquidation is when CBP finalizes the duty assessment for an entry, typically 300–314 days after the entry date.
No. The 180-day deadline is per entry. Each import entry has its own liquidation date and therefore its own protest deadline. An importer with 100 entries may have 100 different deadlines spread across months.
If you miss the 180-day window for an entry, you permanently lose the right to protest that entry and recover the IEEPA duties paid. There are no extensions or exceptions to the 180-day rule under 19 USC 1514.
Yes. CBP allows protests covering multiple entries, provided they involve the same category of merchandise and the same port of entry. Bulk filing can dramatically reduce the time and effort required for importers with many affected entries.
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