How to check entry liquidation status across a whole export, and bucket every entry by its deadlines
Published
Short answer
The legal notice of liquidation is the posting on cbp.gov, dated with the posting date, under 19 CFR 159.9; the courtesy notice your broker receives through ABI is informal. For one entry, look up the posted notice; for a whole export, pull the entry-level liquidation fields from ACE Reports (liquidation status, liquidation date, extension expiration date and number of extensions) and bucket every entry against two clocks: a post-summary correction is possible until 300 days after entry or 15 days before the scheduled liquidation, and a protest until 180 days after the posted liquidation date. Extensions add a year at a time, up to three; suspensions stop the clock until the statute or court order lifts.
TariffSense checks every line of your filed entries against the measures in force on the entry date.
Which date is the liquidation date?
Liquidation is CBP's final computation of the duties on an entry, and it starts the clock that matters most after filing: the 180 days to protest under 19 U.S.C. 1514(c)(3). The date is defined by regulation, not by whichever notice reached you first.
Under 19 CFR 159.9, notice of liquidation for a formal entry is posted on cbp.gov, the notice is dated with the date it is posted, and that electronic posting is the legal evidence of liquidation. CBP keeps the posting available for at least 15 months. The electronic courtesy notice that CBP tries to send the filer and the surety is, in the regulation's words, an informal courtesy notice and not a direct, formal and decisive notice. Brokers forward the courtesy notice; the protest deadline runs from the posting.
There is one exception. An entry that liquidates by operation of law, because CBP did not act within the time 19 U.S.C. 1504 allows, is deemed liquidated on the day the statutory period expired, at the rate, value, quantity and duty the importer asserted (19 CFR 159.11). CBP posts those later, when it works out that the entry deemed liquidated, but dates the posting with the expiry date, and for entries made on or after December 18, 2004 the 180 days run from that date, not from the posting (159.9(c)(2)).
What are the clocks that run from it?
Each entry carries its own set, laid out in full in how long do you have to fix a past entry. For bucketing an export, four of them matter.
| Clock | Runs from | Length | Source |
|---|---|---|---|
| Post-summary correction | Entry date | Until 300 days after entry or 15 days before the scheduled liquidation date, whichever is earlier | CBP PSC test, 91 FR 41053 |
| Liquidation by CBP | Entry date | One year, unless extended or suspended; CBP's normal cycle posts most liquidations earlier, around day 314 (see the deadlines page linked above) | 19 U.S.C. 1504(a); 19 CFR 159.11 |
| Extension | The expiry of the current period | One year per extension, three years of extensions in total; four years from entry is the outer limit unless suspended | 19 CFR 159.12(a), (e), (f) |
| Protest | Posted liquidation date, or the operation-of-law date | 180 days, for entries made on or after December 18, 2004 | 19 U.S.C. 1514(c)(3); 19 CFR 174.12(e) |
Suspension is different from extension. Under 159.12(a)(2), liquidation is suspended as required by statute or court order, most often for entries subject to an antidumping or countervailing duty order while the rate is under review. Nothing runs while the suspension lasts; when it lifts, 19 U.S.C. 1504(d) gives CBP six months from notice of the removal to liquidate, failing which the entry is treated as liquidated at the importer's figures. Notices of extension and suspension are posted on cbp.gov under 159.12(b) and (c), with a courtesy notice through ABI.
Which ACE fields do you pull for a whole export?
Checking one entry means looking up its posted notice. Checking a year of entries means a report. ACE Reports is available to importer and broker accounts, and the entry-level liquidation fields are the ones CBP's own staff work from. CBP's listing of the mandatory entry summary reports its Centers run names the fields on its future-liquidations report: entry summary number, entry type, entry summary date, importer number, liquidation status, liquidation date, liquidation extension expiration date and liquidation extension quantity. CBP's ACE Reports Catalog lists three liquidation reports open to importers and brokers: ES-010 Future Liquidations, for entries scheduled to liquidate; ES-701 Courtesy Notice of Liquidation, for entries that have liquidated; and ES-702 Official Notice of Extension, Suspension and Liquidation. CBP's 2021 message on extended entries points the trade to ES-010 and ES-702. The line-level data itself, HTS numbers, values and duty, comes from ES-003 Entry Summary Line Tariff Details, so the practical build is ES-003 for the lines joined by entry number to the liquidation reports. Whatever the report is called in your account, the fields below are what to look for.
For each entry, the export you build should carry:
- Entry number, entry date and port. The entry date is the anchor for the PSC clock and the one-year limit.
- Liquidation status. Whether the entry is unliquidated, scheduled, liquidated, reliquidated, extended or suspended, as ACE reports it.
- Liquidation date. For a liquidated entry, the posted date; for a scheduled one, the date CBP currently intends. The posting on cbp.gov is the legal record if the two ever differ.
- Extension expiration date and extension count. CBP's guidance to its own liquidation staff says ACE adds one year to the date of entry for each extension, regardless of when the extension was added, and treats the new expiry as the date from which the next cycle runs. With three extensions the fourth anniversary of entry is the end.
- Suspension basis, where the status is suspended, because the PSC test treats some bases as allowing a correction after day 300 and others not.
Ask each broker for these columns in its entry export, or run the reports in your own ACE account; the importer of record's account sees entries filed by every broker under its number. Bucketing is done per entry, so collapse a line-level export to one row for each entry number before you count.
How do you bucket the entries?
With those fields, every entry falls into one bucket, and the bucket decides what an audit finding on it can still become. The table runs the test on November 5, 2026 for six illustrative entries.
| Entry | Entry date | Status in ACE | Key date | Bucket on Nov 5, 2026 | What a finding can become |
|---|---|---|---|---|---|
| A | Sep 10, 2026 | Unliquidated | Scheduled around Jul 23, 2027; day 300 is Jul 7, 2027 | PSC open | PSC for an overpayment or an underpayment |
| B | Jan 8, 2026 | Unliquidated | Day 300 was Nov 4, 2026; scheduled Nov 20, 2026 | PSC closed, awaiting liquidation | Wait for the posting; then protest within 180 days, or disclose an underpayment |
| C | Dec 5, 2025 | Liquidated | Posted Oct 16, 2026 | Protest open until Apr 14, 2027 | Protest an overpayment; disclose an underpayment |
| D | Mar 20, 2025 | Liquidated | Posted Jan 30, 2026; 180 days ended Jul 29, 2026 | Final | Drawback only, for goods exported or destroyed; prior disclosure for an underpayment |
| E | Oct 2, 2025 | Extended, one extension | Extension expiry Oct 2, 2026; new scheduled date in 2027 as ACE shows it | PSC open until 15 days before the new scheduled date | PSC, although day 300 has passed |
| F | Jun 12, 2025 | Suspended, AD/CVD | No scheduled date while the suspension lasts | PSC open while the suspension basis is allowable | PSC on anything other than the suspended issue; the AD/CVD rate waits for the order |
Entry B is the one importers miss. It is still unliquidated, so it looks open, but day 300 passed yesterday and ACE will reject a PSC. The overpayment on it has to wait for the posting and then be protested; the underpayment on it belongs in a disclosure now rather than later.
Entry E shows why the extension fields matter. Its entry date is more than 300 days ago, but the PSC test allows a correction up to 15 days before the scheduled liquidation when liquidation has been extended, so the scheduled date in ACE, not the entry date, decides whether the cheap route is open.
Dates here are illustrative; in your own data, the posted dates on cbp.gov control, and anything filed close to a limit should be confirmed with a licensed customs broker or trade counsel.
How do you keep the buckets current?
- Refresh the export monthly, with the five liquidation fields, and recompute every entry's bucket from its entry date, status, liquidation date and extension expiry.
- Audit the PSC-open bucket first. Entries in it can be corrected either way at the lowest cost, and each day moves some of them into the next bucket. The post-entry audit pillar sets out the line checks.
- Watch the awaiting-liquidation bucket for postings. When an entry moves to liquidated, its 180 days start, and the refund route for anything found on it becomes a protest; how to recover overpaid import duty matches each finding to its route.
- Review the extended and suspended entries separately. Extended entries keep a PSC window that the 300-day rule alone would hide. Suspended AD/CVD entries can wait years and then liquidate within six months of the suspension lifting, so the audit on them should be finished before that happens.
- Record the posted date, not the courtesy date, against every liquidated entry, and keep the record for five years with the entry file.
TariffSense reads broker entry exports in any layout, keeps each entry's entry date and liquidation fields with its lines, and reports each finding with the bucket the entry sits in; the post-entry audit page shows what goes in and what comes back. The buckets are a property of your data and can be computed in a spreadsheet from the five fields above; the filings that follow stay with your broker.
What should you do next on your own entries?
Ask your broker today for the entry export with liquidation status, liquidation date, extension expiry and extension count for every entry in the last twelve months. Count the entries between day 280 and day 300 from entry: those are the ones whose cheapest correction route closes this month, and the ones to audit first.
Sources
- 19 CFR 159.9 Notice of liquidation and date of liquidation for formal entries (ecfr.gov, checked )
- 19 CFR 159.11 Entries liquidated by operation of law (ecfr.gov, checked )
- 19 CFR 159.12 Extension of time for liquidation (ecfr.gov, checked )
- 19 U.S.C. 1504 Limitation on liquidation (govinfo.gov, checked )
- 19 U.S.C. 1514 Protest against decisions of Customs Service (govinfo.gov, checked )
- 19 CFR 174.12 Filing of protests (ecfr.gov, checked )
- Modification and Clarification of the NCAP Test Regarding Post-Summary Corrections, 91 FR 41053 (July 6, 2026) (govinfo.gov, checked )
- CBP ACE messaging, Auto Liquidation of Extended Entries (CAMS #46622865, March 16, 2021) (content.govdelivery.com, checked )
- CBP, ACE Reports Catalog for Trade (ES-003, ES-010, ES-701, ES-702) (cbp.gov, checked )
- CBP, Mandatory Entry Summary/Post Release Report Details (June 2021), attachment to CSMS #48696286 (content.govdelivery.com, checked )
