Tariff refund deadlines by entry date: 80 days, 180 days, and two years

The IEEPA refund process has no single deadline. Each entry has its own clock, and the clock starts at liquidation — CBP's final computation of the duties on that entry. Three windows matter.

Window 1 — 80 days after liquidation: the CAPE limit

CAPE Phase 1 and 2 accept an entry while it is unliquidated or up to 80 days after its liquidation date. On day 81 the entry is "finally liquidated" in CBP's terms and CAPE stops accepting it. There is no fixed calendar date; it is per entry.

Example: an entry liquidated on June 18, 2026 could be filed in CAPE until about September 6, 2026. An entry liquidating on October 1, 2026 stays eligible until about December 20, 2026.

Filing early is the whole game. If your entries are still unliquidated, the declaration itself sets them to liquidate 45 days after acceptance — inside the window by design.

Window 2 — 180 days after liquidation: the protest right

Under 19 U.S.C. § 1514(c)(3) a protest "shall be filed … within 180 days after but not before" liquidation. After that, the liquidation is "final and conclusive upon all persons".

For entries that passed the 80-day CAPE limit, a timely protest is the way to keep the entry open while the Government's appeal of the universal-refund orders is decided. Two cautions from CBP's own guidance: an entry under an open protest is excluded from CAPE, and CBP's IEEPA refunds page (last modified September 30, 2026; read October 8, 2026) states no policy on granting or denying IEEPA protests. Firms handle this differently — compare law firms and brokers that file protests.

Example: liquidated June 18, 2026 → protest by December 15, 2026.

Window 3 — two years: a suit at the Court of International Trade

Where no protest was filed and the entry is finally liquidated, the remaining route is an action under 28 U.S.C. § 1581(i), which must be commenced within two years after the cause of action accrues (28 U.S.C. § 2636(i)). On the start of the clock, Troutman (August 13, 2026) says that the two years are "measured from the date of deposit", and the Congressional Research Service says "potentially" the date the tariffs were paid. On that reading, deadlines for the first IEEPA entries (February 4, 2025) can expire as early as February 2027, and later entries run later. Neither text names a court decision on the start of the clock (read October 8, 2026); ask counsel before relying on any date. The court counted about 3,700 such cases in its July 15, 2026 order; it ordered reliquidation of the plaintiffs' finally liquidated entries on July 17, 2026 (made public July 21; reported).

What is not a deadline

• The CAPE phase dates (Apr 20, Jun 29, and Oct 6, 2026 for Phase 3, as reported; CBP's IEEPA refunds page does not say that Phase 3 is live, read Oct 8, 2026) are start dates, not cut-offs.
• The Federal Circuit's ruling ('anticipated later this year', Troutman, August 13, 2026) may widen or narrow who can be refunded for finally liquidated entries; it does not itself set a filing date.

Put your own dates in

The eligibility checker counts the 80- and 180-day windows from a liquidation date you type. The status tracker lists every dated rule with its source.

General information from public sources, not legal advice; deadlines depend on each entry's dates and on a pending appeal. Checked October 8, 2026.