How Customs Protests Work for IEEPA Duties

A protest is the administrative way to challenge a CBP decision, including a liquidation that included IEEPA duties. It is also what keeps an entry from becoming final.

Deadline

A protest is generally due within 180 days after liquidation (19 U.S.C. 1514). If none is filed, the liquidation becomes final.

Who can file

• The importer or consignee, the surety, or an authorized agent.
• Under 19 CFR 174.3, attorneys and licensed customs brokers can file without a separate power of attorney. Other agents need one.
• A protest prepared for an importer by someone else is customs business and must be prepared by a licensed customs broker or an attorney.

How it is filed

On CBP Form 19, or electronically through ACE (19 CFR 174.12).

How long CBP has to decide

CBP generally has two years to allow or deny a protest (19 U.S.C. 1515). A protester can request accelerated disposition; if CBP does not act within 30 days after that request, the protest is treated as denied. A denial starts the 180-day window to sue in the Court of International Trade.

What CBP has said about IEEPA protests

• CAPE rejects entries with open or suspended protests.
• If a protest was filed only for IEEPA refund purposes and the entry is within 80 days of liquidation, the importer may withdraw the protest and add the entry to a CAPE declaration.

What this means for importers

For entries past the CAPE window but within 180 days of liquidation, a protest is the step that keeps options open. Decide with a licensed customs broker or attorney.

General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.