What is the deadline to claim an IEEPA tariff refund?

There is no single deadline. The deadline depends on which pathway applies. CBP protests must be filed within 180 days of liquidation (19 U.S.C. § 1514). PSCs must be filed before the entry liquidates. Court of International Trade actions under 28 U.S.C. § 1581(i) generally have a 2-year statute of limitations from the date the claim accrued. The CAPE portal, expected to launch late April 2026, only covers unliquidated entries — the deadline there is functionally tied to liquidation. Importers with entries in multiple statuses typically have to track multiple deadlines simultaneously.

IEEPA Tariff Refund Deadlines: Every Clock That Matters

There is no single IEEPA refund deadline. The clock that applies depends on the liquidation status of each U.S. Customs and Border Protection (CBP) entry and which pathway you use. The International Emergency Economic Powers Act (IEEPA) tariffs at issue here are the duties imposed under 50 U.S.C. § 1701 et seq. Most importers are tracking three or four deadlines at once.

The deadline matrix

Pathway	Deadline	Authority	Applies to
Post Summary Correction	Before liquidation (typically within 314 days of entry)	19 C.F.R. § 101.9(b); CBP CSMS	Unliquidated entries
CBP Protest	180 days from date of liquidation	19 U.S.C. § 1514	Liquidated entries
Appeal of denied protest to CIT	180 days from CBP denial	28 U.S.C. § 1581(a)	Denied protests
CIT residual jurisdiction (rights preservation)	2 years from accrual of claim	28 U.S.C. § 1581(i); 28 U.S.C. § 2636(i)	All entries, including post-180-day liquidated
CAPE portal (when live)	Functionally tied to liquidation	CBP announcement, CSMS pending	Unliquidated entries only

The deadline most importers miss

The 180-day CBP protest clock starts on the date of liquidation, not the date of entry and not the date the importer learns of the liquidation. Liquidation can happen automatically by operation of law 314 days after entry under 19 U.S.C. § 1504(a). Many importers never receive direct notice. Pulling Automated Commercial Environment (ACE) entry data is the only reliable way to know which entries have already crossed into the protest window and which have already passed it.

Why the CIT pathway is the safety net

For entries already past the 180-day administrative window, the U.S. Court of International Trade (CIT) still has residual jurisdiction under 28 U.S.C. § 1581(i) for many cases. More than 1,000 companies have already filed protective CIT actions to preserve refund rights. CIT filings are typically inexpensive to file and are often stayed while lead cases play out, making them a low-friction backstop.

Don't guess your deadlines. Tariff Refund Solutions pulls your ACE entry data, classifies every entry by liquidation status, and tells you exactly which clock applies to each. Free eligibility review.

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