All IEEPA Refund Deadlines – 2026
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TL;DR – There is no official deadline to file a CAPE Declaration. The deadlines that matter are Form 19 protest deadlines: approximately June 2026 for February 2025 entries and approximately August 2026 for April 2025 entries. Miss those and you permanently lose refund eligibility on entries outside CAPE Phase 1.
CAPE Phase 1 – No Filing Deadline, But the Window Is Shrinking Every Day
CBP has not set an official closing date for CAPE Phase 1 submissions. But there is a hidden deadline that moves every single day: the 80-day liquidation window.
CAPE Phase 1 only accepts entries liquidated within the preceding 80 days — meaning 80 days before the date you actually file your Declaration, not 80 days from April 20 when Phase 1 launched. Every day you wait, the cutoff date advances by one day, and any entries that cross the 80-day threshold permanently fall out of CAPE Phase 1 eligibility.
In practical terms: an entry that liquidated on February 10, 2026 is eligible if you file today. Wait two weeks and it's no longer eligible — and you'll need to file a Form 19 protest instead, which is slower and more complex.
If you have entries that liquidated in January or February 2026, file your CAPE Declaration now. Those entries are either already at or approaching the 80-day cutoff. Once they cross it, the only remaining path is Form 19 protest.
Form 19 Protest Deadlines
Entries liquidated more than 80 days ago cannot go through CAPE Phase 1. The only remaining option is a Form 19 protest, which must be filed within 180 days of the liquidation date under 19 U.S.C. § 1514.
A standard formal entry liquidates approximately 1 year after the entry date under 19 U.S.C. § 1504. Using that timeline:
| Entry Period | Approx. Liquidation | Protest Deadline | Status |
|---|---|---|---|
| February 2025 | ~December 2025 | ~June 2026 | ⚠️ Approaching |
| March 2025 | ~January 2026 | ~July 2026 | ⚠️ Watch |
| April 2025 | ~February 2026 | ~August 2026 | ⚠️ Watch |
| May 2025 | ~March 2026 | ~September 2026 | Upcoming |
| June–December 2025 | ~April–October 2026 | ~October 2026–April 2027 | Later |
The June 2026 deadline is the most urgent. Importers with February 2025 entries that have already liquidated – and are outside the 80-day window – have until approximately June 2026 to file a Form 19 protest. After that date, those entries are permanently ineligible.
These are approximate dates based on the standard ~1 year liquidation cycle. Your actual liquidation date will vary. Check the Liquidation Date field in your ES-003 report for the exact date on each entry. See How to Pull the ES-003 Report for instructions on adding that field.
The 80-Day CAPE Phase 1 Window
CAPE Phase 1 eligibility depends on where your entry falls relative to its liquidation date:
Unliquidated entries – eligible for CAPE Phase 1 regardless of entry date, as long as the entry date falls within the IEEPA refund window (February 4, 2025 through early February 2026).
Liquidated within the past 80 days – eligible for CAPE Phase 1. CBP will reliquidate and issue a refund. Note: "past 80 days" is calculated from the date you file your Declaration — not from April 20, 2026. The cutoff shifts forward by one day with every passing day.
Liquidated more than 80 days ago – not eligible for CAPE Phase 1. File a Form 19 protest before the 180-day protest deadline instead.
Liquidated more than 180 days ago – no path remaining. Both CAPE Phase 1 and Form 19 protest windows have closed for these entries.
See What Is Liquidation in Customs for a full explanation of liquidation statuses and what each one means for your refund path.
Check CAPE eligibility for one entry
Key Dates Summary
| Date | What It Is |
|---|---|
| February 4, 2025 | Start of IEEPA duty collection – earliest eligible entry date |
| Early February 2026 | End of IEEPA duty collection – latest eligible entry date |
| April 20, 2026 | CAPE Phase 1 launched |
| ~June 2026 | Form 19 protest deadline for February 2025 entries |
| ~August 2026 | Form 19 protest deadline for April 2025 entries |
| No set date | CAPE Phase 1 filing deadline – none announced |
Check Your Entries Against the Deadlines
Upload your ES-003 to see which entries are still eligible for CAPE Phase 1, which require a Form 19 protest and by when, and which are already past both windows — based on the actual liquidation date of each entry.
Drop your ES-003 here
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Frequently Asked Questions
Is there a deadline to file a CAPE Declaration? CBP has not announced a closing date for CAPE Phase 1. However, the 80-day liquidation window is a rolling deadline that advances every single day. Entries that are eligible today may not be eligible next week. Specifically: every liquidated entry crosses the 80-day threshold 80 days after its liquidation date. Once it crosses, it's out of Phase 1 permanently and requires a Form 19 protest instead. File as soon as your ES-003 is ready — if you haven't built the CAPE CSV yet, Liberefund generates it automatically from your ES-003 file.
What happens if I miss the Form 19 deadline? You permanently lose refund eligibility for those entries. The 180-day protest window under 19 U.S.C. § 1514 is a hard statutory deadline – CBP cannot accept late protests. If your February 2025 entries are outside the CAPE window and you haven't filed a Form 19 protest by approximately June 2026, those duties are not recoverable.
My entry was suspended – does the deadline still apply? Suspended entries are included in CAPE Phase 1 and do not face the same 80-day clock as liquidated entries. You can file a CAPE Declaration for suspended entries at any time while Phase 1 is open.
What about entries from May through December 2025? Most of those entries are either still unliquidated or liquidated recently enough to fall within the 80-day CAPE window. Check your ES-003 Liquidation Status field for each entry. If unliquidated or liquidated within 80 days – file CAPE now. If liquidated more than 80 days ago – check whether you're still within the 180-day protest window using your exact Liquidation Date.