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
CBP has not set an official closing date for CAPE Phase 1 submissions. You can file a CAPE Declaration at any time while Phase 1 is open.
That said, the sooner you file, the sooner your entries liquidate and your refund processes. Unliquidated entries are assigned a liquidation date approximately 45 days after CBP accepts your Declaration. The refund payment follows within 60–90 days.
The urgency around deadlines applies to a different process – Form 19 protests for entries that fall outside the 80-day CAPE Phase 1 window.
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 314 days after the entry date. 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 314-day 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.
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.
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 |
Frequently Asked Questions
Is there a deadline to file a CAPE Declaration? CBP has not announced a closing date for CAPE Phase 1. However, entries liquidated more than 80 days before you file will not be accepted – they fall outside the Phase 1 eligibility window. File as soon as your ES-003 is ready.
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.