Maintaining detailed records of IEEPA duties paid is critical because importers have up to 180 days after liquidation to file a protest.
Effective August 7, 2025, the Trump administration imposed tariffs under the International Emergency Economic Powers Act (IEEPA). Imports are subject to 10% tariffs, with some countries at higher rates.
Importers are encouraged to closely track the liquidation status of all entries where IEEPA-related duties were paid and to be ready to file protests. Why is this important? Filing a protest keeps the entry open and protects an importer’s right to a refund if the U.S. Supreme Court ultimately agrees with the lower courts’ decisions that the IEEPA duties are unlawful. For more information on scenarios under various outcomes, this article may be useful.
Customs entries are typically liquidated 314 days after their entry or release date. Therefore, the earliest entries subject to the IEEPA duties are expected to begin liquidating around December; some could occur sooner.
Key takeaway: Maintaining detailed records of all IEEPA duties paid is critical because importers have up to 180 days after liquidation to file a protest.
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