Finally Liquidated Entries, Protests, and Refund Deadlines

Liquidation is CBP's final computation of the duties owed on an entry. Once an entry is liquidated and the time to challenge that liquidation passes, it is "finally liquidated." For IEEPA refunds, that status now decides which route is available.

Why it matters now

• CAPE's first phases covered unliquidated entries and entries still within the correction window after liquidation.
• CBP scheduled Phase 3 for October 6, 2026 to handle finally liquidated entries subject to court-ordered reliquidation, and said these will be processed only for importers who filed their own lawsuits at the Court of International Trade.
• On June 3, 2026, the government appealed the Court of International Trade's refund orders to the Federal Circuit, arguing that relief should be limited to importers who filed their own cases. That appeal is pending.

General deadlines

• Protests generally must be filed within 180 days after liquidation.
• After a protest is denied, an action in the Court of International Trade generally must be filed within 180 days.
• Other court actions have their own limits, and some trade attorneys have pointed to early 2027 as a practical cutoff for claims on the earliest 2025 entries.

These are general rules. Your deadlines run from your own entries' dates. If your entries are finally liquidated or close to it, talk to a trade attorney now.