Imports most at risk of liquidating before the U.S. Supreme Court issues a final decision are entries subject to the China Fentanyl IEEPA tariffs that went into effect on February 4, 2025. Entries filed on or after that date will likely begin liquidating after December 15, 2025, following CBP’s standard 314-day liquidation cycle.
The Mexico and Canada Fentanyl IEEPA tariffs took effect on March 4, 2025. Entries subject to those measures are expected to begin liquidating on or after January 12, 2026 under CBP’s standard liquidation timeline.
The Liberation Day tariffs were implemented on April 2, 2025. Entries covered by those tariffs are projected to begin liquidating on or after February 10, 2026.
If an importer has entries nearing liquidation, the most prudent step is to file a protective action with the U.S. Court of International Trade. The goal is simple: prevent the entries from liquidating while the legal challenges remain unresolved.
Importers have two practical options:
- Request a liquidation extension through their customs broker or trade attorney so CBP delays the liquidation date.
- Have their trade attorney file a protective case with the U.S. Court of International Trade
Note: Importers also retain a post-liquidation option: they have 180 days from the date of liquidation to file a formal protest with CBP. This timeframe is established by statute and cannot be extended.
However, a protest does not prevent liquidation from occurring and generally cannot secure relief for issues tied to broader legal challenges (such as IEEPA tariff disputes). For that reason, the most reliable approach is to prevent liquidation before it happens—either through a CBP liquidation extension or a protective action filed with the U.S. Court of International Trade.
If you have any questions or need guidance on whether your entries are approaching liquidation, feel free to email us. Our team is here to help you review your entries, determine risk exposure, and coordinate the appropriate protective actions before deadlines expire.
