Every import entry has a finish line, and it's called liquidation. It's the point where CBP finalizes the duties, taxes and fees you owe on that entry. Most importers never notice it happen. But liquidation quietly starts and stops most of the clocks that decide whether you can fix a mistake, challenge a charge, or get money back.
If you've read about IEEPA refunds this year and wondered why "liquidated" and "finally liquidated" keep coming up, this is why.
Why it matters
Before liquidation, fixing an entry is relatively easy: you correct it yourself. After liquidation, the easy door closes and you have a fixed window to file a formal protest. Once that window closes too, the entry is final, and getting money back generally takes a court order or a special program like CAPE.
That sequence matters for real dollars. A misclassified product, a missed trade-program claim, or a tariff that was later struck down can all be recovered on entries that are still open. On final entries, the same error can be permanent.
The details
When you file an entry, CBP accepts your declared value, classification and duty as provisional. Liquidation is when it confirms them, or changes them, and posts the result. By law, an entry that CBP hasn't liquidated within one year of entry is "deemed liquidated" at the rate and value you declared (19 U.S.C. § 1504). CBP can extend that deadline, but not past four years from entry. Liquidation can also be suspended, most often for entries subject to antidumping or countervailing duty proceedings, or when a court orders it.
Three tools line up around that date:
Post Summary Correction (PSC). Before liquidation, you can correct an entry summary electronically in ACE. A PSC has to be filed within 300 days of entry and at least 15 days before the scheduled liquidation date (International Trade Insights). This is the cheapest way to fix a classification or valuation error.
Protest. After liquidation, you have 180 days to file a protest challenging CBP's decision, including the duty rate, classification, or the liquidation itself (19 U.S.C. § 1514). If CBP denies the protest, the next step is the Court of International Trade.
Reliquidation. CBP can reliquidate an entry on its own within 90 days of liquidation (19 U.S.C. § 1501), and courts can order reliquidation as a remedy, which is how many IEEPA refunds on older entries are being paid.
An entry becomes "finally liquidated" once the protest window has closed with no protest, or once a protest has been fully resolved. That's the bucket CBP's CAPE Phase 3 is built for: entries that were already final when the Supreme Court held the IEEPA tariffs unauthorized (CBP).
THE LIQUIDATION CLOCK
Deemed liquidation. One year after entry, unless CBP extends it (four years maximum).
Post Summary Correction. Within 300 days of entry and at least 15 days before scheduled liquidation.
Reliquidation by CBP. Within 90 days after liquidation.
Protest deadline. 180 days after liquidation. Miss it and the entry is final.
What to do about it
Know your liquidation dates. ACE reports show liquidation status and dates by entry. Ask your broker for a report covering at least the last two years.
Put protest deadlines on a calendar. Count 180 days from each liquidation date. Protests are often the last cheap chance to recover an overpayment.
Fix errors before liquidation. If you find a classification or value mistake on an open entry, a PSC is faster and simpler than a protest later.
Check your IEEPA entries by status. Unliquidated, liquidated-but-protestable and finally liquidated entries follow different refund paths — ask your broker for a status breakdown before you file anything against a CAPE-eligible entry. IEEPA refund services like Evana can also sort your entries by status from your ACE data; Evana isn't a brokerage, but its team of licensed customs brokers files the CAPE claims.
Remember drawback claims liquidate too. Without accelerated payment, you're not paid until the claim itself liquidates.
Our read
Liquidation used to be back-office plumbing. The IEEPA refund process turned it into one of the most important dates on an entry, and it will stay that way whenever tariffs are challenged in court. The habit to build is simple: know which of your entries are open, which are protestable, and which are final, before you need to act on any of them.
Related on Trade Talk: CAPE Phase 3: Who Qualifies, What to Expect, and Key Dates · CAPE Phase 3 Opens Oct. 6 — Here's Who's Locked Out · Duty Drawback, Explained
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