How long do you have to fix a past entry? Liquidation and the deadlines that run per entry

Why do deadlines run per entry, not per finding?

An audit finds a pattern: a product classified under the wrong heading, a Chapter 99 duty that should not have been there, freight left in the value. The fix, though, is made entry by entry, and every entry has its own dates. An error repeated across forty entries over a year has forty sets of clocks, and on the day the audit finishes some of those entries are still open to a cheap correction, some can only be protested and some are closed.

Most of the clocks start from one of three dates on the entry:

• The entry date (block 7 of Form 7501), usually the release date. The post-summary correction window and the liquidation deadline run from it.
• The liquidation date, the date CBP posts the liquidation on cbp.gov. The protest window, CBP's own 90-day reliquidation window and CAPE's 80-day limit run from it.
• The date of importation. The 1520(d) trade-agreement claim and drawback run from it.

Liquidation is the hinge. It is the point at which CBP fixes the duty on the entry, and the moment that closes the post-summary correction route and opens the protest route.

Which clocks run on every entry?

The sections below explain the ones that cause the most missed recoveries.

When does an entry liquidate?

By law, an entry not liquidated within one year of the entry date is deemed liquidated at the rate, value, quantity and duty the importer declared (19 U.S.C. 1504(a); 19 CFR 159.11). In practice CBP liquidates well before that. Its post-summary correction guidance refers to the 314-day liquidation cycle, which puts most entries' liquidation about ten and a half months after entry.

The liquidation date is the date CBP posts the notice of liquidation on cbp.gov. 19 CFR 159.9 makes that electronic posting the legal evidence of liquidation and keeps it online for at least 15 months. CBP also tries to send an electronic courtesy notice to the filer and the surety, but the regulation describes it as informal; a protest deadline is never counted from it. Ask your broker to report each entry's posted liquidation date, or check it in ACE.

Can liquidation be extended or suspended?

Yes, and either one moves every clock that runs from liquidation.

• Extension. Under 19 U.S.C. 1504(b) and 19 CFR 159.12, CBP may extend liquidation by up to one year at a time when it needs information to classify or appraise the goods, or when the importer asks in writing before the period expires and shows good cause. Total extensions cannot exceed three years, so an extended entry liquidates by operation of law four years after entry at the latest. CBP posts the notice of extension on cbp.gov.
• Suspension. Liquidation is suspended when a statute or court order requires it, most often for entries covered by an antidumping or countervailing duty order while Commerce sets the final rate. When the suspension is lifted, CBP has six months from notice to liquidate, after which the entry is treated as liquidated at the declared amounts (19 U.S.C. 1504(d)).

An importer who finds a problem late in an entry's life can ask for an extension to keep the post-summary correction route open. With an extension granted, CBP's guidance says the PSC no longer has to be filed within 300 days of entry, only 15 days before the new scheduled liquidation date. Since August 5, 2026, the PSC test notice of July 6, 2026 (91 FR 41053) also accepts PSCs past 300 days for entries whose liquidation is suspended beyond that point for AD/CVD, EAPA or a court injunction, a practice CBP says it had allowed since 2022.

How long is the post-summary correction window?

300 days from the entry date, or until 15 days before the scheduled liquidation date, whichever is earlier. ACE rejects a PSC filed outside that window automatically, according to CBP's guidance. On CBP's normal 314-day cycle the two limits fall within a day or two of each other, so treat day 299 as the practical end.

The window also closes early in other ways: a PSC cannot be filed while the entry is under CBP review, before it is paid or after it has gone on a CAPE Declaration for an IEEPA refund.

How long do you have to protest after liquidation?

180 days after the date of liquidation or reliquidation (19 U.S.C. 1514(c)(3)). For a decision that does not involve a liquidation, such as the denial of a 1520(d) claim, the 180 days run from the date of that decision (19 CFR 174.12(e)). For an entry liquidated by operation of law, they run from the date the statutory period expired (19 CFR 159.9(c)(2)).

Entries made before December 18, 2004 had 90 days, which is why older guidance still mentions that figure.

A protest is filed with CBP, in the ACE protest module or on paper. CBP then has two years to decide it (19 CFR 174.21), or 30 days after a request for accelerated disposition (19 CFR 174.22). A denial, or the absence of a decision 30 days after that request, starts another 180-day clock: the time to sue in the Court of International Trade (28 U.S.C. 2636(a)).

Which clocks run from importation instead of liquidation?

Two recovery routes ignore liquidation altogether, and they are easy to miss because nothing on the entry's own timeline warns you before they close.

• 1520(d) trade-agreement claims. When goods qualified under an agreement such as USMCA but were entered without the claim, the importer has one year after the date of importation to claim the refund (19 U.S.C. 1520(d)). On CBP's usual cycle the entry liquidates around day 314, so the 1520(d) deadline falls only weeks later, and it runs whether or not the entry has liquidated.
• Drawback. A drawback claim must be filed within five years of the date the goods were imported (19 U.S.C. 1313(r)); claims not completed in that time are treated as abandoned.

Reconciliation also runs from the start: 21 months from the oldest flagged entry summary for value, classification and 9802 issues, 12 months from importation for FTA claims, with no extensions according to CBP's guidance.

How long can CBP come back for an underpayment?

Longer than you can come back for an overpayment. Under 19 U.S.C. 1621, CBP has five years from the date of the violation to bring a penalty action or recover lost duties under section 1592, or five years from discovery where the violation was fraud. Entry records must be kept for five years from the entry date (19 CFR 163.4).

That asymmetry is the reason an audit reports both directions. An overpayment on an entry liquidated a year ago is usually lost; an underpayment on the same entry is still open to CBP. A prior disclosure under 19 CFR 162.74, made before CBP opens a formal investigation, is the way to correct it and limit the penalty.

Do IEEPA and Section 122 entries have different deadlines?

IEEPA. The Supreme Court held on February 20, 2026 that IEEPA does not authorize tariffs, and CBP refunds IEEPA duties through CAPE. CBP's CAPE notice (updated July 10, 2026) accepts entries that are unliquidated or up to 80 days past their liquidation date, which keeps them inside the 90 days in which CBP can reliquidate on its own under 19 U.S.C. 1501. Entries that are suspended or extended keep that status and are refunded at liquidation. Entries liquidated more than 90 days ago, which the Court of International Trade calls finally liquidated, need a court order: CAPE Phase 3, deployed October 6, 2026, opened them only to plaintiffs whose cases carry a reliquidation order, and a class of importers who did not sue was certified on October 8, 2026 (Freestyle World, Inc. v. CBP, Slip Op. 26-123). [OWNER REVIEW: has the court ordered class-wide relief, or has CBP opened CAPE to class members, since October 27, 2026? If not, keep this sentence as written.] For which entries qualify, see IEEPA refunds: which entries qualify.

Section 122. The surcharge under Proclamation 11012 applied to goods entered from February 24, 2026 until it lapsed at 12:01 a.m. on July 24, 2026, when a Section 301 action on forced labor took over. On CBP's 314-day cycle, the first of those entries are scheduled to liquidate from early January 2027, which is when their 180-day protest clocks begin. The Court of International Trade held the surcharge unlawful on May 7, 2026, but enjoined it only for three plaintiffs (Oregon v. United States, Slip Op. 26-47). [OWNER REVIEW: has the government appealed Oregon v. United States, and is there any refund route for Section 122 duty paid by importers who were not plaintiffs? Neither was found in a primary source on October 27, 2026; if still unknown, keep this sentence as written.]

How do the clocks run on one entry, from release to final?

Take one illustrative entry, released and imported on December 1, 2025, a product of China, with a line that carried an IEEPA duty and a Section 301 duty. Assume CBP posts its liquidation on Friday, October 16, 2026, about 319 days after entry.

An audit run on October 27, 2026 still catches this entry for a protest and a CAPE declaration, but not for a post-summary correction. The same audit run in April 2026 would have caught it while every route was open. An audit run in May 2027 would find the overpayments closed, with only drawback and the underpayments still open.

Filing dates near any of these limits should be confirmed with your licensed customs broker or trade counsel, who can check the posted dates in ACE.

How do you track the clocks across all your entries?

1. Pull every entry for the last five years from your broker's export, with entry date, importation date, liquidation status and posted liquidation date.
2. Compute each clock from the table above for every entry, including extensions and suspensions shown in ACE.
3. Mark the entries inside each window today: PSC, protest, 1520(d), CAPE.
4. Run the audit on those entries first, starting with the windows that close soonest.
5. Repeat monthly, so every new entry is audited while the post-summary correction window is still open.

TariffSense reads entry summaries and broker entry exports in any layout and checks every line against the measures in force on its entry date, so the findings come with the entry dates already attached. The post-entry audit page shows what goes in and what comes back. For which route each finding takes, see how to recover overpaid import duty; for what to check on each line, see the post-entry audit pillar and Form 7501 field by field. To check the rate on one line for its date, use the duty calculator.

What should you do next on your own entries?

Ask your broker for a list of every entry from the last twelve months with its entry date and posted liquidation date. Count how many are still unliquidated, how many liquidated in the last 180 days and how many were imported in the last year under a supplier that could qualify for USMCA. Those three groups are the entries where an audit can still change the money, and the first group closes one entry at a time, every day.