Before You File for an IEEPA Refund: Why Liquidation Status Changes Everything

Most importers calculating their IEEPA refund exposure are focused on one question: how much did I overpay? That's the right question. But it's the second question. The first, and the one that determines what you can actually do, is: which of my entries have already liquidated?

Liquidation status determines your filing path. Get it wrong and you may miss the window, file using the wrong mechanism, or both. This post explains the difference, how to find out where your entries stand, and how to use Triangle's free calculator to quantify the amount before you engage your broker or attorney.

Two Paths. One Decision Point.

When CBP liquidates an entry, it finalizes the duties owed. That moment of liquidation splits your IEEPA refund options into two completely different tracks:

A Post Summary Correction is filed electronically through ACE while the entry is still open. It's generally faster and less costly than a protest. A protest is a formal legal challenge filed after liquidation. It requires more documentation and has a hard 180-day deadline from the date of liquidation.

Many entries affected by IEEPA tariffs are still unliquidated. That window, while the PSC path is still available, is exactly what compliance teams are racing to identify right now.

How to Find Out Which Entries Have Liquidated

This is where most teams get stuck. Standard canned reports in ACE show liquidation summaries, but they don't give you the granular, entry-level visibility you need to make filing decisions.

The better approach, highlighted this week by Robert Dunlap, Manager of Global Trade Compliance at a major importer, is to use the ACE Entry Summary Universe to build a custom ad hoc report. The Entry Summary Universe includes detailed liquidation data elements, including the ability to split out MPF and other fees that may or may not be refundable under IEEPA.

CBP has published a step-by-step guide to creating custom ad hoc reports in ACE using the Web Intelligence tool. The process: choose the Entry Summary Universe, add liquidation date, entry number, and IEEPA-related duty fields as result objects, and filter by the period when IEEPA tariffs were in effect (before February 20, 2026). That gives you an entry-by-entry view of liquidation status and duty exposure.

If your team hasn't used the ACE Entry Summary Universe before, the custom report approach takes some setup, but it's the most reliable way to get accurate, entry-level liquidation data rather than aggregate summaries.

What You Need Before Filing a PSC

Once you know an entry is unliquidated, there is preparation work before you file. CBP guidance is specific about what a complete PSC package looks like:

• Original CBP Form 7501 data
• Commercial invoice, packing list, and bill of lading
• Classification analysis and valuation support
• Origin documentation (USMCA certificate if applicable)
• Corrected duty calculations with the resulting bill or refund amount

There is one requirement that stands out for IEEPA refund claims specifically: if you are seeking a refund for duties paid under IEEPA, those amounts must be prominently identified and distinguished from duties paid under other tariffs still in force, such as Sections 232 or 301.

That is not a minor detail. It means you cannot submit a single blended duty figure. IEEPA exposure needs to be broken out separately from your Section 301 China tariffs and your Section 232 steel or aluminum tariffs before your broker or attorney can file.

What Triangle Handles: The Tariff Math

The ACE report tells you which entries and when. Triangle tells you how much, broken out the way CBP requires.

IEEPA rates were not uniform. They varied by country of origin, by whether the rate was a fentanyl surcharge or a reciprocal tariff, and by how the entry interacted with Section 301 and Section 232. For the same HS code, an entry from China carried a different IEEPA exposure than an entry from Vietnam or India.

Triangle's free IEEPA Refund Estimator calculates your estimated IEEPA exposure by HS code and country of origin. It returns:

• IEEPA tariff paid, split between fentanyl surcharge and reciprocal tariff
• Section 301 rate separately identified (Section 301 was not struck down)
• Section 232 rate separately identified where applicable
• What your effective rate looks like now under Section 122
• The net change: what you overpaid vs. what applies today

That separation is exactly what the PSC guidance requires. Use the ACE report to identify the entries. Use Triangle to get the layer-by-layer breakdown. Bring both to your licensed customs broker or trade attorney before filing.

The Timeline Is Compressing

The Supreme Court ruled on February 20, 2026. Entries that liquidated in the weeks before the ruling are already on the 180-day protest clock. Entries that liquidate in the coming weeks will start their own clock immediately.

Entries that haven't liquidated yet are still in PSC territory, but that window closes the moment CBP processes liquidation, and you'll have no advance notice of when that happens for any specific entry.

The compliance teams moving now are the ones who will have the clearest picture of their exposure and the most options. The ones waiting for clarity will find themselves in protest-only territory by the time they act.