Reliquidation
Reliquidation is the process by which U.S. Customs and Border Protection (CBP) reopens a previously finalized (liquidated) import entry to correct the duty amount owed. In the context of the 2026 tariff refunds, reliquidation is the legal mechanism through which importers receive refunds for IEEPA tariffs that the Supreme Court ruled unconstitutional.
How Reliquidation Works
Normal Liquidation
When you import goods, CBP reviews your entry and finalizes the duty amount — this is called liquidation. Once liquidated, the entry is considered settled. Liquidation typically occurs within 314 days of entry.
When Reliquidation Happens
Reliquidation reopens a liquidated entry to adjust the duties. This can occur due to:
- Court order — A court directs CBP to recalculate duties (as in the IEEPA refund case)
- Successful protest — An importer files CBP Form 19 and CBP agrees the original duty assessment was wrong
- Administrative review — CBP discovers an error in classification, valuation, or rate application
- Changed circumstances — A retroactive change in tariff policy or trade agreement
The Reliquidation Process
- CBP identifies entries eligible for reliquidation
- CBP recalculates duties using the corrected rate or authority
- The difference between the original and corrected duty amount is determined
- Refunds are issued to the importer of record (via ACH through the ACE Portal)
- Entry records are updated in the ACE system
Reliquidation in the 2026 IEEPA Refund Context
The Court of International Trade's March 4, 2026 order directed CBP to reliquidate all entries where IEEPA tariffs were collected. This involves:
- 53 million entries from 330,000 importers
- Approximately $166 billion in total refunds
- Entries spanning April 2025 through February 2026
Two Categories
| Entry Status | Reliquidation Path | Action Required |
|---|---|---|
| Unliquidated (not yet finalized) | CBP reliquidates without IEEPA duties automatically | No importer action needed |
| Liquidated within 180 days | CIT order directs CBP to reliquidate | File protest (CBP Form 19) to preserve rights |
| Liquidated beyond 180 days | May require separate legal action | Consult trade attorney |
Key Terms
- Liquidation: The final computation of duties on an import entry
- Reliquidation: Reopening a liquidated entry to correct the duty amount
- Protest (CBP Form 19): The formal mechanism to challenge a liquidation decision; must be filed within 180 days
- ACE Portal: CBP's electronic system where entries are managed and refunds processed
Related: Tariff Refunds for Small Businesses | IEEPA | Duty Drawback