IEEPA refund deadline: it counts from each entry’s liquidation date

As of September 24, 2026

There is no single deadline. Every entry has its own clock that starts on its liquidation date: CAPE accepts entries liquidated within the last 80 days, and a protest is due within 180 days of liquidation. Unliquidated entries have no clock running yet.

What liquidation is

Liquidation is the date CBP finalizes the duties on an entry. CBP usually liquidates an entry about 314 days after entry, and ACE posts liquidations weekly on Fridays. It can happen sooner, and CBP can extend it.

So a 2025 entry made in March probably liquidated around January 2026, and one made in November probably liquidates around September 2026. Your actual dates are in ACE.

The two windows

CAPE window: CBP’s CAPE process takes unliquidated entries and entries no more than 80 days past liquidation. CBP set 80 days so it can process the refund and reliquidate within the 90-day voluntary reliquidation period under 19 U.S.C. 1501. Past 80 days, CAPE rejects the entry with "Entry Summary is in Final Liquidation Status".

Protest window: 180 days from liquidation to protest under 19 U.S.C. 1514. An entry past CAPE’s 80 days can still be inside this window. An entry on an open or suspended protest cannot also go on a CAPE Declaration.

After 180 days with no protest, liquidation is final. CBP lists entries whose liquidation is final as a future CAPE phase, still under evaluation, with no date.

How to find each entry’s liquidation date

Log in to the ACE Portal with your importer account.
Run a liquidation or entry summary report for your importer number covering your 2025 entries, or ask your broker for the list.
For each entry, add 80 days to the liquidation date for the CAPE window and 180 days for the protest window.
Sort by the earliest date. Those entries come first.

Interest

CBP pays interest on the refunded duties under 19 U.S.C. 1505, from the deposit date to liquidation or reliquidation, at the quarterly overpayment rates set under 26 U.S.C. 6621 and compounded daily. From January 2025 through 2026 the corporate rate is 6%, except 5% in the second quarter of 2026; the non-corporate rate is 7%, except 6% in that quarter.

FluxFina’s estimate projects interest to 90 days after today, since CBP pays interest up to reliquidation and that date is not known in advance. CBP’s paid figure is the real one; any figure before it is a projection.

Sources

Sources checked September 24, 2026.

FluxFina prepares documents for the importer of record or their licensed customs broker. It is not legal or customs advice, and FluxFina never files with CBP. Only the importer of record or its broker can file a CAPE Declaration or a protest.