Guides

    How to Check Entry Liquidation Dates in ACE

    Strix Customs Team · Licensed Customs Brokers · October 13, 2026 ET · 13 min read

    Liquidation · ACE · IEEPA Refunds · CAPE · Section 122 · Post Summary Corrections · Protests

    Strix Customs Team

    Each customs entry has its own liquidation date, and every refund or correction deadline that matters right now is counted from it. You can check that date yourself in two places. One is U.S. Customs and Border Protection's (CBP's) public Official Notice of Extension, Suspension and Liquidation, which anyone can search by entry number, filer code, or importer number. The other is the ES-701 and ES-702 reports inside your account on the Automated Commercial Environment (ACE), the system CBP uses to process import filings. The date that counts legally is the one on the posted notice, not the one in a courtesy email.

    This guide is written as of Tuesday, October 13, 2026. It covers where to look, how to read what you find, and what the date means for IEEPA refunds through CAPE and for Section 122 surcharge entries. If you read it later, check the dated statements against CBP's current pages before relying on them.

    Why your deadline is a list of dates

    It is tempting to look for "the" IEEPA refund deadline or "the" Section 122 deadline. There isn't one. The recovery windows that apply in October 2026 are counted from the date each entry liquidates. Liquidation is CBP's final computation of the duties owed on an entry. An importer with 400 entries has 400 liquidation dates, so it has 400 sets of deadlines.

    CBP's own numbers show what happens when nobody checks. In a declaration filed with the Court of International Trade (CIT) on September 15, 2026, CBP reported that 6.1 million entries submitted on CAPE refund declarations had failed entry-level validation. The first reason it listed was that the entry was "past CBP's 90 day re-liquidation authority." CAPE (Consolidated Administration and Processing of Entries) is the tool CBP built in ACE to refund duties paid under the International Emergency Economic Powers Act (IEEPA). That is a timing failure, and checking dates first is how you avoid it.

    So the work this week is simple to state: for every entry you care about, find the liquidation date and write it down.

    When entries normally liquidate

    A few facts tell you roughly where to look before you open anything.

    Formal entries usually liquidate about 314 days after entry. CBP told the CIT in a March 6, 2026 declaration that ACE "is programmed to automatically liquidate entries 314 days after the date of entry into the United States, unless liquidation is extended or suspended in accordance with law, or a CBP user manually removes the entry from this automated process." The same declaration says "the majority of entries automatically liquidate." It also says CBP runs that batch "each Friday, starting at 02:00 AM ET." Your entry won't liquidate on day 314 exactly. It will liquidate in the Friday run near that day.

    One year is the legal limit, and 314 days is CBP's working schedule. Under 19 U.S.C. § 1504(a) and 19 CFR 159.11, an entry that isn't liquidated within one year of entry is "deemed liquidated" at the rate and amount the importer declared. CBP schedules liquidation at 314 days so entries don't run out the clock. Use 314 days to plan and the one-year limit as the outside boundary.

    Informal entries liquidate when you pay. Under 19 CFR 159.10(a)(1), an informal entry (for example, an entry type 11) liquidates on "the date of payment by the importer of duties due on the entry." CBP's March declaration says the same. An informal entry does not wait 314 days. Its liquidation date is effectively its payment date, so any post-liquidation clock started then.

    Extensions and suspensions move the date. Under 19 CFR 159.12, CBP may extend liquidation by up to one year at a time when it needs more information or when the importer shows good cause. Extensions may total no more than three years. Under 19 U.S.C. § 1504(b), an extended entry is treated as liquidated at four years at the latest. Suspension is a separate status, applied "as required by statute or court order." Entries subject to antidumping or countervailing duties (AD/CVD) are the common case: according to CBP's March declaration, ACE suspends their liquidation automatically until the Department of Commerce sends instructions. If an entry carries AD/CVD, 314 days tells you nothing about it. You have to look it up.

    Where to look: the public liquidation bulletin

    CBP's Official Notice of Extension, Suspension and Liquidation is at trade.cbp.dhs.gov/ace/liquidation/LBNotice. You don't need an ACE login to use it. The page says it "provides public notice for liquidation actions for entry summaries" under 19 CFR Part 159.

    As of October 13, 2026, you can search it by:

    • Entry number (the fastest way to check a single entry)
    • Filer code
    • Importer of Record number
    • Surety code and Port of Entry
    • Date ranges: liquidation, posted, entry, and voided dates
    • Event type: Suspended, Extended, Re-liquidated, Liquidated
    • Entry type, codes 01 through 52

    Two details on that page affect how you use it. Data goes back to January 14, 2017, and the page says notices are "archived for 15 months." That matches 19 CFR 159.9, which requires CBP to keep each notice posted for at least 15 months. If an entry liquidated more than 15 months ago, it may no longer be on the bulletin, and you'll need ACE reports or your filer's records. The page also says it updates daily, and that manual liquidations usually appear within about 90 minutes of processing.

    To check a batch of entries, search by your importer number and a liquidation date range rather than one entry number at a time. Export the results and compare them with your own entry list. Any entry on your list that isn't in the results is either still unliquidated or outside the date range you searched.

    Where to look: ACE reports

    If you have an ACE Portal account, CBP's IEEPA refunds page (last modified September 30, 2026) points to two reports:

    • ES-701, Courtesy Notice of Liquidation. This lists liquidations for your entries. For entries where liquidation changed the duty, CBP says it includes "the amount of the bill or refund."
    • ES-702, Official Notice of Extension, Suspension and Liquidation. This is the report version of the public bulletin, and it shows extensions and suspensions as well as liquidations.

    CBP says "an importer or broker with an ACE Account may access" both reports, and that ACE users "can set their accounts to schedule reports." Scheduling is the part most teams skip. If you schedule ES-702 to run every week after the Friday liquidation batch, you'll see new liquidations within days instead of finding them at quarter-end.

    For IEEPA refunds specifically, the same CBP page lists three more reports: ES-022 (CAPE Entry Summary), which links declarations, entries, and refunds; REV-603, which shows refund status such as "Sent to Treasury" and "Treasury issued"; and REV-615, the CAPE refund detail report. Those reports track refunds. ES-701 and ES-702 are the ones that show liquidation dates.

    If you don't have an ACE Portal account, ask your customs broker for an ES-702 export covering your importer number. As of this writing, CBP's refunds page also says you need the "Importer" sub-account in the ACE Portal to enter refund bank information. Even if your broker runs the reports, you'll need your own account to receive a refund.

    Which date counts: the posting, not the courtesy notice

    Under 19 CFR 159.9, the notice of liquidation for a formal entry is posted on CBP's website, and "this electronic posting will be deemed the legal evidence of liquidation." The courtesy notice CBP tries to send the filer is, in the regulation's words, an "informal, courtesy notice." It is not the legal notice.

    In practice:

    • Count deadlines from the liquidation date on the posted notice (the bulletin or ES-702).
    • Treat ES-701 and any broker email as a reminder. If its date doesn't match the bulletin, go with the bulletin.
    • If an entry shows Re-liquidated, the reliquidation date starts a new clock for the issues that reliquidation decided. Write down both dates.

    Reading a bulletin entry

    Each result row has a few fields that matter for your decision.

    Event type tells you the entry's status. "Liquidated" or "Re-liquidated" means post-liquidation clocks are running. "Extended" or "Suspended" means the entry is not yet liquidated, so pre-liquidation tools such as a Post Summary Correction (PSC), the ACE amendment that fixes an entry before it liquidates, may still apply.

    Basis tells you why CBP took the action. The search options include Deemed Liquidation, Manual Liquidation, Customs Extension, and Court Ordered Suspension. A deemed liquidation means the entry ran out the statutory clock and was liquidated as you entered it. A court-ordered suspension means you should ask counsel which case the suspension comes from.

    Action tells you which way the money moved: Change Increase (CBP assessed more), Change Decrease (CBP assessed less, so a refund is due), or No Change. If a Change Increase or a No Change liquidation still includes a duty you believe wasn't owed, the protest clock is the one to watch.

    Turning a liquidation date into deadlines

    Once you have the date, four numbers follow from it. All of them come from statute or from CBP's published rules. None of them depends on a CBP decision.

    Days after liquidation What it governs Source
    80 Last day CAPE accepts a liquidated entry ("liquidated within the preceding 80 days") CBP IEEPA Duty Refunds page
    90 End of CBP's voluntary reliquidation authority 19 U.S.C. § 1501
    180 Protest deadline: "within 180 days after but not before" liquidation 19 U.S.C. § 1514(c)(3)

    Before liquidation, a different clock applies. CBP's Post Summary Correction page says a PSC can be filed "within 300 days from the date of entry and up to 15 days of the scheduled liquidation date, whichever date is earlier." On the standard 314-day schedule, the 15-day limit falls around day 299, so it usually comes first. Because the actual liquidation runs on a Friday near day 314, that limit can come a few days earlier. Plan around whichever date is earlier for each entry. After liquidation, that same CBP page says the options are "a prior disclosure or a protest."

    A worked example, using our own arithmetic. Suppose the bulletin shows an entry liquidated on Friday, September 4, 2026. Day 80 is November 23, 2026. Day 90 is December 3, 2026. Day 180 is March 3, 2027. As of today, October 13, that entry is on day 39. If it qualifies for CAPE, it has 41 days left to go on a declaration. It can be protested until early March. Work from your own dates, not this example.

    What to do with the date: IEEPA entries

    As of September 30, 2026, CBP's IEEPA refunds page describes CAPE as covering certain unliquidated entries and entries liquidated within the preceding 80 days, plus, since June 29, 2026, entries flagged for reconciliation where no type 09 reconciliation entry has been filed yet. Entries in a liquidated, extended, or suspended status can all appear on one declaration: CBP says you "can file all eligible entry summaries on one CAPE declaration, whether or not they have liquidated." If an entry is past day 80, ACE rejects it with the error "Entry Summary is in Final Liquidation Status."

    Sort your IEEPA entries into three groups:

    1. Unliquidated, extended, suspended, or liquidated within 80 days. These are CAPE candidates now. Every week you wait brings a liquidated entry closer to day 80. Our IEEPA refund deadline tracker explains how to build the inventory and who is allowed to file.
    2. Liquidated more than 80 days ago but within 180 days. CAPE's current build won't take these. A protest under 19 U.S.C. § 1514 is still within its window. CBP's page names a protest as the way to dispute a CAPE refund decision. It does not say a protest is how CBP will refund IEEPA duties on an older entry. Decide entry by entry with counsel, and note that CBP won't accept an entry on a CAPE declaration while it has an open protest.
    3. Liquidated more than 180 days ago. As of September 30, CBP's page lists "entries for which liquidation is final" among the categories it is still "evaluating" for later deployments, with no date. In its September 15 declaration, CBP told the CIT it would deploy CAPE Phase 3 on October 6, 2026. Phase 3 covers finally liquidated entries "filed by plaintiffs for which the Court has ordered reliquidation." The Court of International Trade's October 8 opinion in Freestyle World confirms it: "On October 6, 2026, Customs deployed CAPE Phase 3." CBP's own public refunds page does not yet describe Phase 3. Our post on CAPE Phase 3 explains why it applies only to plaintiffs. For anyone else, this group is a question for a trade attorney.

    Once you file a CAPE declaration, CBP says you can't submit a PSC or a protest for the entries on it, and you can't withdraw the declaration. If an entry has a separate, non-IEEPA error that needs a PSC, decide that before the entry goes on a declaration.

    What to do with the date: Section 122 entries

    The 10% Section 122 surcharge applied to goods entered from 12:01 a.m. on February 24, 2026 through 12:01 a.m. on July 24, 2026, under Proclamation 11012. As of October 13, 2026, CBP's trade remedies index (last modified October 1, 2026) lists no Section 122 refund program. We found no merits decision in the government's appeal (Nos. 2026-1804 and 2026-1805) on the Federal Circuit's public opinions-and-orders listing as of its October 9 releases. Our Section 122 refund status post covers what the CIT actually decided and the June 11 stay.

    For those entries, the liquidation date drives everything:

    • On the standard schedule, these entries are still unliquidated. By our arithmetic, 314 days after February 24, 2026 is January 4, 2027. For the last surcharge entries in late July, it is early June 2027. The statutory one-year limit sits about seven weeks after each of those dates. Extensions or suspensions would move any individual entry, so check the bulletin rather than assuming.
    • Before liquidation, use a PSC to fix real errors. A missed exemption, a wrong classification, or a wrong value can be corrected now. Removing the surcharge line just because you think it was unlawful is a different thing, and the appeal hasn't decided that question. For the earliest entries, the 300-day mark is December 21, 2026, and the 15-day rule may land a few days before that.
    • After liquidation, the protest clock starts. Under § 1514(c)(3), you can't protest before liquidation. Once the bulletin posts the date, you have 180 days. Put both dates on your calendar now so a January liquidation isn't missed.

    The Section 122 surcharge page lists the exemption categories, and a missed exemption is the most common correctable error on these entries.

    Make the check routine

    ACE liquidates formal entries in a weekly batch, so check weekly too. A routine that works:

    1. Keep one master list of entries with entry number, entry date, filer code, entry type, and the tariff programs on each line (IEEPA Chapter 99, 9903.03.01, Section 301, AD/CVD).
    2. Add a projected date of entry date plus 314 days for each formal entry, and mark any AD/CVD entries as "check manually."
    3. Schedule ES-702 to run after the Friday batch, or search the bulletin by importer number for the past week's liquidation dates.
    4. Replace each projected date with the posted date as entries liquidate, and calculate day 80, day 90, and day 180 from it.
    5. Assign an owner for every entry that is within 30 days of any of those dates.

    Search the entry number on CBP's Official Notice of Extension, Suspension and Liquidation at trade.cbp.dhs.gov/ace/liquidation/LBNotice. No login is required. If you have an ACE Portal account, the ES-702 report shows the same information for all your entries. If the entry isn't there and is less than about 314 days old, it most likely hasn't liquidated yet.

    Is the liquidation date the date on my broker's courtesy notice?
    Not necessarily. Under 19 CFR 159.9, the electronic posting on CBP's website is "the legal evidence of liquidation," and the courtesy notice is informal. Count your 80-day, 90-day, and 180-day deadlines from the posted date.

    My entry isn't on the bulletin. Does that mean it hasn't liquidated?
    Usually, but not always. The bulletin keeps notices for 15 months and starts in January 2017, so an older liquidation may have dropped off. Informal entries liquidate when duties are paid and get their notice on the duty receipt, not through a bulletin posting. If you can't find an entry, check ACE reports or ask the filer.

    Can I still file a PSC once I know the liquidation date?
    Only if the entry hasn't liquidated yet. CBP's rule is 300 days from entry or 15 days before scheduled liquidation, whichever comes first. After liquidation, CBP says the remaining options are a prior disclosure or a protest. For IEEPA duties, CBP's refund process is CAPE.

    How we help

    We work with importers in four modes. For liquidation tracking, here is what each one covers:

    • Consult. We pull your liquidation dates from ACE and the bulletin, sort each entry by the next deadline it faces, and mark which entries need a CAPE decision, a PSC decision, or a conversation with counsel.
    • Comply. We prepare and file Post Summary Corrections for real pre-liquidation errors at $150 per PSC entry, covering up to 10 lines. We also check that your ACE Portal and refund bank details are in place. Details are on our Post Summary Corrections page and our IEEPA and CAPE refund review.
    • Clear. We keep your current entries moving with full brokerage at $100–$250 per entry while the refund work runs.
    • Automate. If your team wants to file its own entries and see its own liquidation data, self-filing runs $30 per entry.

    We don't give legal advice, and we can't predict what CBP will accept or refund on any entry. What we can do is make sure every entry's date is known and on your calendar before its deadline passes. Talk to our team if you want a second set of eyes on your entry list.


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