Why deadlines matter: miss them and lose your refund permanently
The right to claim an IEEPA tariff refund is not indefinite. Customs law imposes strict filing deadlines that cannot be extended, waived, or appealed once they pass. If you miss the deadline for a particular entry, you permanently forfeit the refund for that entry. There is no late filing provision and no hardship exception.
The stakes are substantial. The IEEPA tariff was 10% of the customs value of every import for approximately one year. A company importing $5 million in goods during the IEEPA period paid roughly $500,000 in IEEPA duties alone. With 6% interest, the total recovery could exceed $530,000. Missing a filing deadline on even a single large entry could mean leaving tens of thousands of dollars on the table.
The complexity is compounded by the fact that different entries have different deadlines depending on their liquidation status. You cannot apply a single deadline across your entire portfolio. Each entry must be tracked individually.
Two paths based on entry status
Path 1: Unliquidated entries use Post Summary Corrections (PSCs). If your entry has not yet been liquidated by CBP, you can file a PSC to amend the entry summary and remove the IEEPA tariff component. PSCs must be filed before the entry liquidates. There is no filing fee. The PSC is processed as part of the normal liquidation cycle, and the IEEPA duty amount is refunded when the entry liquidates at the corrected rate.
Path 2: Liquidated entries require protests using CBP Form 19. If your entry has already been liquidated, you must file a formal protest within 180 days of the liquidation date. The protest cites the Supreme Court ruling as grounds for reliquidation and refund of the IEEPA duty component. Protests are reviewed by CBP port directors and, if approved, result in reliquidation and refund.
The distinction is critical. PSCs are simpler, faster, and have a more flexible filing window (any time before liquidation). Protests are more formal, have a hard 180-day deadline, and take longer to process. Identify which path applies to each of your entries immediately.
How to check your entry status in ACE
Log into the Automated Commercial Environment (ACE) portal at ace.cbp.dhs.gov using your importer credentials. Navigate to the Entry Summary section and filter entries by date range (February 2025 through February 2026) and by tariff chapter or duty type to identify entries with IEEPA duty components.
For each entry, ACE displays the liquidation status: unliquidated, liquidated (with date), or suspended. Entries marked as unliquidated are eligible for PSC filings. Entries marked as liquidated require you to note the exact liquidation date and calculate your 180-day protest deadline.
If you do not have direct ACE access, your customs broker can pull this data on your behalf. Request a full entry status report covering the IEEPA period. Ensure the report includes entry number, entry date, liquidation status, liquidation date (if applicable), and the IEEPA duty amount for each entry.
Key dates calendar for IEEPA refunds
February 20, 2026: Supreme Court ruling invalidating IEEPA tariffs. This is the triggering event for all refund claims. IEEPA tariff collection ceases.
February 24, 2026: IEEPA tariffs officially terminated by executive action. Section 122 surcharge takes effect as replacement. CBP begins accepting PSCs and protests for IEEPA refund claims.
Rolling deadlines: 180-day protest windows per entry. Each liquidated entry has its own deadline calculated from its individual liquidation date. For example, an entry liquidated on December 1, 2025 has a protest deadline of May 30, 2026. An entry liquidated on January 15, 2026 has a deadline of July 14, 2026.
Ongoing: Unliquidated entries must have PSCs filed before liquidation. Most entries liquidate within 314 days of entry, but timing varies. Monitor ACE for estimated liquidation dates.
Estimated processing: 3 to 4 months from filing for CBP to process refunds. Early filers will receive refunds sooner. ACH enrollment must be completed before CBP will release payment.
Dollar amounts at stake: average refund per entry
The IEEPA refund amount per entry depends on the customs value of the imported goods. The IEEPA tariff was 10% ad valorem, so the refund equals 10% of the declared customs value plus 6% annual interest from the deposit date.
For a typical $25,000 customs value entry, the IEEPA duty was $2,500. With interest at 6% for 12 months, the total refund is approximately $2,650. For a $100,000 entry, the refund is approximately $10,600 including interest. For high-volume importers with hundreds of entries, total refund amounts can reach hundreds of thousands or millions of dollars.
CBP collected an estimated $80 to $100 billion in IEEPA tariffs during the 12-month period. The total refund liability, including interest, is substantial. CBP has indicated it will process refunds on a first-filed, first-processed basis, which creates an additional incentive to file early.
Common mistakes that void your refund claim
Filing a protest after the 180-day deadline. This is the most common and most costly mistake. The deadline is absolute. CBP will deny late protests without review. Track every entry's liquidation date individually.
Failing to enroll in ACH refund program. CBP will not issue refund payments to importers who are not enrolled in the ACH program. Enrollment takes 5 to 10 business days. Do not wait until your refund is approved to enroll. Enroll now.
Filing under the wrong importer of record number. The refund claimant must match the IOR on the original entry. If your company has changed its importer of record number, EIN, or CBP bond information since the original entry, ensure the protest or PSC uses the correct original IOR information.
Omitting the IEEPA tariff component from the PSC or protest. Your filing must specifically identify the IEEPA duty amount and cite the Supreme Court ruling. Generic duty adjustment requests may be rejected or delayed. Be precise in your filings.
Not tracking interest correctly. Interest accrues from the date of duty deposit, not from the date of the Supreme Court ruling. Ensure your refund calculations use the correct deposit date for each entry to maximize your interest recovery.
How Refund Assistant tracks all your deadlines automatically
The NormSuite Refund Assistant at refund.normsuite.com is purpose-built for IEEPA refund management. It connects to your entry data, classifies each entry by liquidation status, calculates exact refund amounts including interest, and tracks every filing deadline across your entire portfolio.
The tool generates automated alerts when protest deadlines are approaching, flags entries at risk of liquidation (so you can file PSCs in time), and monitors ACH enrollment status. It provides a consolidated dashboard showing total refund exposure, filed claims, pending refunds, and completed payments.
For importers managing dozens or hundreds of entries across the IEEPA period, manual tracking in spreadsheets is error-prone and time-consuming. A single missed deadline on a high-value entry can cost more than the annual subscription to an automated tracking tool. Refund Assistant eliminates that risk.