IEEPA Tariff Refund Deadlines: How Long Do You Have to File Your Claim?
When the Supreme Court invalidated the IEEPA tariffs, it triggered a massive administrative effort by U.S. Customs and Border Protection (CBP) to process an estimated $175 billion in refunds. For small business importers, the most pressing question is not just how to get their money back, but when they have to ask for it.
The deadlines for filing an IEEPA tariff refund claim are complex, unforgiving, and entirely dependent on the specific legal status of your individual customs entries. Missing a deadline by a single day can permanently forfeit your right to recover thousands of dollars in overpaid duties.
Here is a clear breakdown of the critical deadlines you need to understand to protect your business’s financial interests.
The 180-Day Protest Window for Liquidated Entries
The most rigid and dangerous deadline in customs law applies to liquidated entries. As we explained in our guide to liquidation status, a liquidated entry is one where CBP has finalized the duty assessment.
Under 19 U.S.C. § 1514, a liquidation decision becomes final and binding on both the importer and the government unless it is formally protested within 180 days of the date of liquidation.
This 180-day clock is statutory, meaning CBP has almost no legal authority to extend it or grant exceptions for late filings. If your entry was liquidated 181 days ago, your right to protest that specific entry—and claim a refund for the IEEPA tariffs paid on it—is generally gone forever.
Because liquidation happens on a rolling basis for each individual entry, your business does not have a single deadline. You have a unique 180-day countdown running for every single shipment you imported during the tariff period. You must run an entry report through the ACE Secure Data Portal immediately to identify which of your entries are approaching this critical cutoff.
The CAPE Portal Timeline for Unliquidated Entries
If your entries are unliquidated (meaning CBP has not yet finalized the assessment), you are in a much better position. Because the assessment is still open, the 180-day protest window has not yet started ticking.
For these entries, CBP has built the CAPE (Consolidated Administration and Processing of Entries) portal. This automated system went live on April 20, 2026.
While unliquidated entries do not face the immediate threat of the 180-day protest bar, you should not delay your CAPE Declaration submission. CBP has indicated they aim to process CAPE claims within 60 to 90 days of submission, but the system is handling an unprecedented volume of requests. The longer you wait to file, the further back in line you will be for your refund.
Furthermore, an unliquidated entry can be liquidated by CBP at any time. If you wait to file your CAPE Declaration and CBP liquidates the entry in the meantime, you will suddenly be thrust into the 180-day protest window, significantly complicating your claim.
The Cost of Delay: Lost Interest
Beyond the hard legal deadlines, there is a financial cost to delaying your claim. The government is generally required to pay statutory interest on unlawfully collected duties, accruing daily from the date you paid the tariffs.
For corporate taxpayers, this interest rate is tied to the IRS quarterly underpayment rate (typically around 6%). For non-corporate entities, it is often around 7%.
While this interest increases the value of your refund over time, it stops accruing once CBP issues the refund check. More importantly, if you miss a deadline and forfeit the principal, you also forfeit all the accrued interest.
Do Not Miss Your Window
The complexities of customs deadlines mean you cannot afford to guess about your entry status. You need a comprehensive audit of your import history to identify every approaching 180-day deadline and prioritize your filings.
The Dayes Law Firm IEEPA tariff refund lawyers have the experience to audit your ACE data, determine the exact deadlines for your liquidated and unliquidated entries, and file the necessary protests and CAPE Declarations to secure your recovery.
Do not let the clock run out on your refund. Call us today at (866) 609-9774 for a consultation on your tariff refund deadlines.