IEEPA Tariff Refund Timeline

IEEPA Tariff Refund Timeline - International trade, tariff & customs attorneys. CBP defense. Call (818) 514-7680.

International Trade & Customs Law Services

Comprehensive customs and tariff defense for California importers at the Port of Los Angeles, Port of Long Beach, and all U.S. ports of entry. Services include CBP audit defense, tariff classification, customs valuation, Section 301/232/IEEPA tariff strategy, UFLPA forced labor compliance, duty drawback recovery, and Court of International Trade litigation.

Current Tariff Landscape

With effective tariff rates at historic highs, California businesses need experienced trade counsel. We handle Section 301 China tariffs, Section 232 steel/aluminum tariffs, IEEPA tariff refund claims, and reciprocal tariff compliance.

Free consultation for importers: (818) 514-7680.

Filed Court of International Trade Actions

Trembach Law Firm is not only admitted to the U.S. Court of International Trade — it has filed 3 complaints there. The actions are docketed at the Court of International Trade as 26-02506, 26-02846, 26-04095. Anatolii Trembach is admitted to practice before the Court of International Trade and is licensed in California, State Bar #349304, verifiable at apps.calbar.ca.gov.

This matters for IEEPA refunds specifically. The Court of International Trade has ordered CBP to reliquidate and refund on plaintiffs’ entries, and CBP’s CAPE Phase 3 for finally liquidated entries is likewise available only to importers who are plaintiffs at the Court. An importer who never filed has no confirmed, self-executing mechanism. Choosing counsel who has actually filed at that court, rather than counsel who only describes the process, is therefore a practical question and not a marketing one.

Jurisdiction over these actions rests on 28 U.S.C. § 1581, and the window to sue runs under 28 U.S.C. § 2636(i). No particular outcome is promised or guaranteed.

Fees, Costs and Case Results

Representation in these matters is offered on a contingency basis covering attorney fees only: there is no attorney fee unless we recover, and clients remain responsible for case costs, such as court filing and service fees. The specific terms that apply to a matter are set out in the written fee agreement for that matter.

Where this site refers to a verdict, settlement or court order, that result was dependent on the facts of that case, and results will differ if based on different facts. Past results do not predict or guarantee the outcome of any other matter, and no particular outcome is promised or guaranteed.

Frequently Asked Questions

What is the most important deadline for IEEPA tariff refunds?
The single most important deadline is the 180-day protest filing period after entry liquidation. Once an entry is liquidated by CBP, you have exactly 180 days to file a protest under 19 USC 1514. Missing this deadline permanently forfeits your right to recover the IEEPA tariffs paid on that entry through the administrative process. Because entries liquidate on a rolling basis, importers must continuously monitor their entries and file protests before each deadline expires.
How long does CBP take to liquidate an entry?
Under 19 USC 1504, CBP must liquidate an entry within 314 days of the date of entry. However, CBP may extend the liquidation period for up to one year at a time, with a maximum extension of four years from the date of entry. CBP may also suspend liquidation indefinitely in certain circumstances, such as pending litigation or government investigation. If CBP does not liquidate within the statutory period and has not extended or suspended liquidation, the entry is deemed liquidated at the rate of duty asserted by the importer.
What happens if an entry is deemed liquidated?
Under 19 USC 1504, if CBP fails to liquidate an entry within the statutory period (314 days, as extended), the entry is deemed liquidated at the rate of duty asserted at the time of entry. For IEEPA tariff entries, this means the entry is deemed liquidated at the rate that included IEEPA duties (because the importer declared IEEPA duties at entry). You may still need to file a protest to recover the IEEPA component of the deemed liquidation amount.
What is the deadline to file a CIT summons after a protest denial?
You must file a summons in the U.S. Court of International Trade within 180 days of the date CBP denies your protest. This deadline is jurisdictional and cannot be extended. If CBP does not act on your protest within two years, the protest is deemed denied, and the 180-day CIT filing period begins from the date of deemed denial. Missing the CIT summons deadline permanently bars judicial review.
What is a Post-Summary Correction (PSC) and when must it be filed?
A Post-Summary Correction (PSC) under 19 CFR 173.4 allows an importer to amend an entry summary before liquidation. For IEEPA tariff refunds, a PSC removes the IEEPA duty component from the entry before CBP finalizes it. The PSC must be filed before the entry is liquidated. The standard deadline is within 300 days of the date of entry, but PSCs can be accepted closer to liquidation. Because PSCs avoid the need for a formal protest, they are often the fastest path to recovering IEEPA duties on unliquidated entries.
How do I check whether my entries have been liquidated?
You can check liquidation status through the Automated Commercial Environment (ACE) portal. Log into ACE and navigate to the Entry Summary section to view the liquidation status of each entry. Your customs broker can also run liquidation reports showing the status of all entries filed on your behalf. Additionally, CBP posts liquidation notices in the CBP Bulletin, which is available online. Proactive monitoring of liquidation status is essential for timely filing of protests and PSCs.
Can CBP suspend liquidation of IEEPA tariff entries?
Yes. CBP has the authority to suspend liquidation of entries in certain circumstances, including when ordered by a court or when requested by the government in connection with pending litigation. If a court orders suspension of liquidation in connection with IEEPA tariff litigation, entries covered by the suspension order will not be liquidated until the suspension is lifted. Suspended entries remain open and can be reliquidated in accordance with any court judgment. Check with your customs broker or attorney to determine whether any of your entries are subject to a suspension of liquidation.
What is the interest rate on IEEPA tariff refunds?
Under 19 USC 1505, interest on refunded duties accrues from the date the duties were deposited with CBP to the date of the refund. The applicable interest rate is set quarterly by the Secretary of the Treasury based on the federal short-term rate. The rate is published in the Federal Register and on the CBP website. Interest can add a significant amount to the refund, particularly for entries where duties were paid many months or years before the refund is issued.
What happens to entries filed in February through June 2025?
Entries filed from February through June 2025 are among the earliest subject to IEEPA tariffs and may be approaching or have already passed the standard 314-day liquidation period. Many of these entries may already be liquidated, meaning the 180-day protest deadline is running or may have already expired. Importers should immediately check the liquidation status of all entries from this period and file protests for any liquidated entries that are still within the 180-day window. For entries that have already passed the protest deadline, consult a trade attorney about alternative remedies.
Should I wait for CBP guidance before taking action?
No. Waiting for CBP guidance is dangerous because statutory deadlines continue to run regardless of whether CBP has issued guidance on IEEPA tariff refunds. The 180-day protest deadline and the liquidation timeline are not paused by the absence of official guidance. Importers should take immediate action to identify their qualifying entries, file protests on liquidated entries, and file PSCs on unliquidated entries. You can always supplement your filings with additional information once CBP guidance is issued.

Contact Trembach Law Firm

Trembach Law Firm, APC

27001 Agoura Road, Suite 350, Calabasas, CA 91301

Phone: (818) 514-7680

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