Liquidation

Liquidation is the point at which CBP finalizes the classification, value, rate and amount of duty, taxes and fees on an entry. Everything paid on the entry summary (CBP Form 7501) is an estimate; liquidation either confirms it as entered or changes it, and CBP bills the increase or refunds the excess. The rules are in 19 U.S.C. 1504 and 19 CFR part 159.

When entries liquidate

• Scheduled liquidation: an entry summary with no issue for CBP to review is set up in ACE for liquidation 314 days after entry. Liquidations post weekly, on Fridays
• Deemed liquidation: an entry not liquidated within one year of the date of entry is deemed liquidated at the rate, value, quantity and amount of duty the importer asserted (19 U.S.C. 1504(a))
• Extension: CBP can extend the period by up to one year at a time when it needs information for classification or appraisement, or when the importer shows good cause; the entry cannot stay open past four years from entry (19 CFR 159.12, 19 U.S.C. 1504(b))
• Suspension: liquidation is suspended where a statute or court order requires it, most commonly on antidumping and countervailing duty entries until Commerce sets the final rate. CBP must then liquidate within six months of being notified that the suspension is removed (19 U.S.C. 1504(d))

How notice is given

The legal notice of liquidation is posted on cbp.gov, and its posting date is the date of liquidation (19 CFR 159.9). Brokers and sureties filing electronically also receive courtesy notices, but the posted notice is the one that counts, so the 180-day protest clock can start without anyone being told directly.

Correcting an entry before and after liquidation

• Before: a post-summary correction can be filed within 300 days of entry and no later than 15 days before the scheduled liquidation date, whichever is earlier
• After: a protest under 19 U.S.C. 1514, filed within 180 days after liquidation, contests CBP's decisions on classification, rate, value, charges and the liquidation itself. It can be filed in the ACE protest module by the importer, its surety or its customs broker (19 CFR part 174)

Once the 180 days pass without a protest, liquidation is final and binding. That is why duty refund claims, such as the IEEPA tariff refunds, depend on the entries still being open or protested in time.

Why liquidation matters to an importer

An increase at liquidation is billed to the importer of record, and the customs bond stays liable for it. Keep the entry file until the entry is final, watch the liquidation date on every entry that may be owed a refund, and ask your broker for an ACE liquidation report. The tariff refunds guide explains how liquidation timing affects IEEPA and Section 122 refund claims.