Status: Following the Supreme Court’s February 2026 ruling against the IEEPA tariffs, CBP is issuing refunds through CAPE in phases. Phase 1 covers unliquidated entries and entries within 80 days of liquidation. Last reviewed June 2026.
The short version
There is no single IEEPA refund deadline. Two different clocks matter. For the CAPE refund process, Phase 1 covers unliquidated entries and entries that liquidated within the past 80 days, with later phases reaching older entries. Separately, the administrative protest right under 19 U.S.C. § 1514 generally runs for 180 days from the date of liquidation. Because these windows move forward every day, the only reliable way to know your deadlines is to pull your entries and sort them by liquidation date.
Why are the deadlines per entry instead of one date?
Customs deadlines are tied to liquidation — the point at which CBP finalizes the duties owed on an entry. Since every entry liquidates on its own schedule, the recovery clock starts on a different day for each one. That is why a single importer can have some entries that are urgent, some comfortably inside the CAPE window, and some already closed, all at the same time.
What is the Form 19 protest deadline?
Under 19 U.S.C. § 1514, a protest must generally be filed within 180 days of the date of liquidation. This is a hard statutory window. Once it closes, the entry has “finally liquidated” and the administrative protest path is normally no longer available. For IEEPA recovery, this is the deadline that most often catches importers off guard, because it runs independently of whatever is happening with the CAPE program.
What is the CAPE window?
CAPE Phase 1 covers two groups: entries that are still unliquidated, and entries that liquidated within the past 80 days. CBP removes the IEEPA duty lines from those entries, recalculates, and re-liquidates with interest. Entries that liquidated more than 80 days ago fall outside Phase 1 — but they are not necessarily lost. The Court of International Trade has addressed refunds for entries with final liquidations, and CBP announced later phases (2 and 3) to reach them. They simply cannot use the Phase 1 route.
How do I calculate my own deadlines?
- Pull your entry/duty report from ACE (or have your broker pull it).
- For each entry, note the liquidation date.
- Add 180 days to the liquidation date — that is the outer protest deadline.
- Flag any entry whose protest deadline is within the next 60 days as urgent.
- Separately flag unliquidated entries and entries that liquidated within the past 80 days as CAPE Phase 1 candidates.
Frequently asked questions
If I miss the 180-day protest window, is the refund gone?
The administrative protest path generally closes at 180 days. Whether any other avenue remains for a finally liquidated entry depends on how the broader IEEPA matter resolves and on what a future phase covers. Treat the 180-day window as firm and act before it, rather than counting on a later remedy.
Can an entry be eligible for both CAPE and a protest?
An entry can fall within both windows at once, but you generally pursue one path per entry. Coordinate with your broker before filing so you do not create a conflict between a pending protest and a CAPE declaration on the same entry.
Does the CAPE deadline ever “expire” for everyone at once?
No. Because eligibility is entry-specific and time-based, the practical effect is a rolling cutoff rather than a single closing date. New entries age into and out of eligibility continuously.
Related guides
- The complete guide to IEEPA tariff refunds
- Form 19 protests for IEEPA duties
- How to file a CAPE declaration
Easy Logistics is an independent resource and is not affiliated with U.S. Customs and Border Protection. This is general information as of June 2026, not legal advice. The 180-day protest window and your specific entry deadlines should be confirmed with a licensed customs broker or trade attorney.