The 180-day protest deadline under 19 U.S.C. section 1514 is the single most time-sensitive element of IEEPA tariff recovery. Once it passes on a liquidated entry, the standard protest path is gone permanently. The entry can still be pursued through Court of International Trade (CIT) litigation, but that path is slower, more expensive, and less certain.
Following the February 2026 Supreme Court ruling in Learning Resources v. Trump (6-3 decision, $166 billion in IEEPA tariffs struck down), importers face a paradox: they have strong legal claims, but those claims expire on a per-entry basis. Understanding your specific timeline is not optional — it is the difference between a straightforward protest and a multi-year court proceeding.
What the deadline means
After CBP liquidates a customs entry — typically 314 days after the entry date — the importer of record has exactly 180 days to file a formal protest challenging the assessed duties. For IEEPA entries filed during the covered period (February 2025 through February 2026), this means the earliest entries may have protest deadlines approaching in mid-2026.
The deadline is per-entry, not per-importer. An importer with 200 entries may have 200 different deadlines. Some entries may be safely within the window. Others may be weeks away from expiration. A full Impact Assessment at tariffresolution.com maps every entry to its specific deadline.
How to check your timeline
There are two ways to determine your liquidation status:
Option A: Ask your customs broker. Send this message: “Can you check the liquidation status of my entries from February through December 2025 that include HTS codes 9903.01 or 9903.02? I need to know which are liquidated and the liquidation dates.”
Your broker can pull this from the ACE portal in minutes. The liquidation date is the key data point — add 180 days to determine your protest expiration for each entry.
Option B: Check ACE directly. If you have ACE Secure Data Portal access, run the ES-003 Entry Summary Line Levels Detail report and filter for liquidation status. The liquidation date field shows when the 180-day clock started on each entry. For step-by-step instructions, see pulling your ES-003 from ACE.
The math on current deadlines
If an entry was liquidated on December 15, 2025, the 180-day protest window expires on June 13, 2026. That is less than three months from the date of this writing.
The earliest IEEPA entries were filed in February 2025 under executive orders targeting China (EO 14195), Canada (EO 14193), and Mexico (EO 14194). With a typical 314-day liquidation cycle, those entries may have been liquidated around December 2025 — putting their protest deadlines in the June to August 2026 range.
Entries filed later in 2025 (including “Liberation Day” reciprocal tariffs from April 2025 under EO 14257) will have later liquidation dates and later protest deadlines. But importers with entries across the full IEEPA period likely have a mix of urgent and non-urgent deadlines.
What happens if you miss the 180-day window
Missing the protest deadline does not eliminate your claim entirely, but it significantly changes your options:
CIT litigation becomes the primary path. The Court of International Trade can review customs duty assessments, but filing requires a trade attorney, involves court fees, and takes months to years. For large claims, this may be worthwhile. For smaller claims, the economics may not justify the cost.
Post-summary correction is unavailable. This path only applies to unliquidated entries. Once an entry is liquidated and the protest window closes, correction is no longer an option.
Claim acquisition may still be available. Institutional buyers at tariffbuyouts.com evaluate claims based on legal strength, not just protest window status. Claims with CIT viability may still qualify for immediate capital, though pricing reflects the additional complexity.
The three recovery paths by entry status
The eligibility checker assesses whether you likely qualify for IEEPA refunds, but your specific recovery path depends on entry status:
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Unliquidated entries — Post-summary correction. Your customs broker files an amendment removing IEEPA tariff codes. Fastest path, typically days to weeks. No protest deadline applies.
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Liquidated, within 180 days — Formal CBP protest under 19 U.S.C. section 1514. Your customs broker or trade attorney files a protest challenging the IEEPA assessment. Processing takes weeks to months.
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Liquidated, past 180 days — CIT litigation under 28 U.S.C. section 1581. Requires a trade attorney. Timeline is months to years. See what happens after you qualify for details on all four recovery paths.
Unliquidated entries: a different kind of urgency
If your entries have not yet been liquidated, you do not face the 180-day deadline — but you face a different form of urgency. CBP could liquidate these entries at any time, which would start the 180-day clock. Filing a post-summary correction before liquidation is the simplest recovery path available.
The eligibility checker helps you determine whether you have IEEPA exposure. But only your actual entry data reveals which entries are liquidated and which are not. Your customs broker or the ES-003 report from the ACE portal provides this information.
What to do right now
If you have not yet checked whether your entries are approaching this deadline, do so now. The process takes minutes, not days:
- Screen your eligibility — confirms whether you likely have IEEPA exposure (two minutes, no data required)
- Contact your customs broker or check ACE for liquidation dates on IEEPA entries
- For entries with protest deadlines within 90 days, initiate the protest process immediately
- For a comprehensive analysis of all entries, request a full Impact Assessment at tariffresolution.com
CBP has 2,500 staff processing 53 million affected entry lines. The queue will only lengthen. Customs brokers and trade attorneys in the partner network at tariffpartners.com can assist with urgent protest filings if your broker of record is at capacity.
Do not wait until the deadline is imminent to discover you had one.