When does an entry liquidate?

The 314-day default

Under 19 USC 1504(a), CBP has one year from the date of entry to liquidate. In practice, CBP's automated liquidation system triggers at approximately 314 days (10.5 months) from entry. At liquidation, the entry's duty, classification, and valuation become legally final.

If CBP does not act within one year, the entry is "deemed liquidated" at the rate originally declared by the importer — often called "deemed liquidation."

Why liquidation date is critical for refunds

Liquidation starts two clocks:

1. CF-19 protest clock (180 days) — Under 19 USC 1514(c)(3), the importer has 180 days from liquidation to file a protest challenging the classification, duty, or other liquidation decision. Miss this and the liquidation is irrevocable.
2. Refund disbursement clock — CBP computes final duty at liquidation. Any refund owed flows from liquidation math, with interest per 19 USC 1505.

For CAPE IEEPA refunds, unliquidated entries process without CF-19. Liquidated entries must have a CF-19 filed within 180 days. See CAPE Phase 1 eligibility.

Finding the liquidation date

Three sources:

• ACE Portal — Liquidation Report — Filter by IOR and date range. Shows status (unliquidated, liquidated, suspended) and date.
• CBP Liquidation Bulletin — Published weekly at www.cbp.gov. Lists entries liquidated during the prior week, by port.
• Form 7501 — The 7501 itself does not show liquidation date; that date is added afterward in CBP's system and appears in the bulletin and ACE.

Pull the full liquidation report for all entries in the IEEPA window. This is the spine of your refund eligibility analysis.

Suspensions and extensions

Liquidation can be extended beyond 314 days under 19 USC 1504(b) for:

• Antidumping or countervailing duty proceedings pending
• Court orders
• Importer requests (rare)
• Administrative review periods

If your entry is suspended, the liquidation clock pauses. Common in ADD/CVD contexts. Check ACE for "suspended" status.

Maximum extension under 19 USC 1504(b) is generally 4 years from entry. Beyond that, deemed liquidation applies regardless.

Deemed liquidation

If CBP fails to liquidate within one year (or the permitted extension period), 19 USC 1504(a)(1) deems the entry liquidated at the rate originally declared by the importer. Deemed liquidation can work for or against an importer:

• For: If CBP was planning to upgrade duty and missed the deadline, the original declared rate stands
• Against: If the importer declared a higher rate than necessary and CBP missed deemed date, the opportunity to lower it via reliquidation is gone

For IEEPA refund purposes, deemed liquidation at the IEEPA-inclusive rate is not helpful. You want active CAPE processing before deemed liquidation freezes the entry.

Reading the Liquidation Bulletin

The weekly bulletin lists:

• Port code
• Entry number
• Importer name
• Liquidation date
• Liquidation action (liquidated as entered, reliquidated, etc.)

Download the bulletin for your port of entry and search by entry number. This is especially important for entries near the 180-day protest window.

Extended liquidation (reliquidation)

CBP may reliquidate under 19 USC 1501 within 90 days after the original liquidation, generally for CBP-initiated corrections. After 90 days, only a CF-19 protest can reopen an entry. Reliquidation effectively extends the 180-day protest clock because the clock restarts on reliquidation.

Calculating the protest deadline

Entry date: March 1, 2025 Default liquidation: January 9, 2026 (314 days later) CF-19 deadline: July 8, 2026 (180 days after liquidation)

For IEEPA-window entries, build a spreadsheet with entry date, projected liquidation date, and protest deadline. Sort by protest deadline ascending. File the earliest-expiring protests first.

What to do if a deadline is approaching

If a liquidated entry is within 30 days of its 180-day CF-19 expiration:

1. Pull the 7501 and liquidation bulletin entry
2. Confirm IEEPA duty line present
3. Draft CF-19 citing the Feb 20, 2026 SCOTUS ruling as grounds under 19 USC 1514(a)
4. File electronically via ACE Protest Module
5. Do not wait for CAPE — CAPE is administrative; CF-19 is your legal preservation

See the IEEPA refund guide for the protest template and procedure.

Calculate your tariff refund → /calculators/ieepa-refund

Related questions

What's the difference between 3461 and 7501? See 3461 vs 7501.

Which entries qualify for CAPE? See CAPE eligibility.

Does CBP pay interest on refunds? Yes, from date of deposit. See refund interest.

Not legal advice. Customs business performed by licensed customs broker partners under 19 CFR 111.