PSC, Protest, CAPE, or Drawback: Which Refund Pathway Fits Each Entry

The four pathways on one table

As of June 11, 2026. Liquidation dates vary entry by entry, so verify every window below against your own entries with your broker before relying on it.

This article is part of The Manufacturer's Guide to Checking Your Tariff Bill. The rest of this page walks each pathway, then routes a worked entry through the tree.

Post Summary Correction: the cheap, fast door

A PSC amends an entry that has not yet liquidated. It reaches back 300 days from the entry date, and it must land no later than 15 days before scheduled liquidation, whichever comes first. While the door is open it is the pathway of choice: a post summary correction refund is an administrative fix your broker files in the normal course of business, no litigation posture required. The catch is the second deadline. Liquidation is scheduled by CBP, not by you, so a finding can be inside 300 days and still miss the 15-day cutoff. Get the scheduled liquidation date from your broker before assuming the PSC door is open.

Protest: the absolute clock

Once an entry liquidates, the PSC door closes and the protest door opens: CBP Form 19, within 180 days of the liquidation date. The deadline is absolute. There are no extensions, no equitable exceptions, no second chances. This is the clock that makes overpayment checking a scheduled activity rather than a someday activity, because entries liquidate continuously and each liquidation starts a 180-day fuse on whatever errors that entry carries. Verify liquidation dates entry by entry with your broker; they are the whole game here.

A protest is also a substantive filing, not a form with a checkbox: it names the entries, the decision being protested, and the grounds, with the evidence attached. That is why line-level documentation matters as much as the date. A protest backed by the invoice text, the rate in force on the entry date, and the arithmetic is a different filing from a protest that says "we believe we overpaid."

CAPE: IEEPA only, and only some of that

CAPE is CBP's system for refunding the IEEPA duties struck down on February 20, 2026, live in ACE since April 20, 2026. Phase 1 covers unliquidated entries and entries liquidated within roughly 80 days of submission; only the importer of record or the original filing broker can file; and reconciliation, drawback-flagged, AD/CVD, and finally-liquidated entries are excluded. CAPE cannot rule on classification, valuation, or origin: it refunds the IEEPA math and nothing else.

The frontier question is finally-liquidated entries. The Court of International Trade ordered universal refunds; DOJ appealed to the Federal Circuit on June 2, 2026; and as of June 11, 2026 the appeal is pending, with CBP and DOJ maintaining they lack authority to refund entries more than 180 days past liquidation without an importer-specific judgment. If you hold finally-liquidated IEEPA entries, that is a conversation for your counsel, not a CAPE filing. For rejected declarations and batch rules, see the CAPE rejection guide.

Drawback: the five-year reach, for exporters

Drawback refunds up to 99 percent of eligible duties on goods that were subsequently exported or destroyed, and it reaches back five years from import, by far the longest window of the four. Section 301 and Section 122 duties are drawback-eligible. Section 232 duties are not.

The honest math for a mid-market manufacturer: drawback pays when meaningful duty sits on goods that demonstrably left the country, and it costs real recordkeeping, because every claim ties import paperwork to export paperwork. If you export little, the other three pathways are your program. If you export steadily and have never filed, five years of eligible duty is sitting in the window, and a conversation with your broker about a first claim is worth having.

Liquidation is the master clock

Notice what three of the four windows have in common: they pivot on liquidation, a date CBP sets and you do not. Liquidation closes the PSC door, opens and then closes the protest door, and defines finally-liquidated status for CAPE. Entries liquidate continuously, on their own schedules, which is why a year of entries never has one deadline; it has hundreds, scattered across the calendar. The single highest-value piece of data in any recovery effort is the liquidation date per entry, current, from your broker or your ACE account. Everything else in this article is arithmetic on top of those dates.

The decision tree, on one entry

One shipment, entered February 10, 2026, three lines, checked in June 2026:

• Line 1: an IEEPA duty line. The program was struck down; the refund routes through CAPE, eligibility permitting. Nothing else on this entry can travel in that filing.
• Line 2: a missed 301 exclusion. The entry date is inside 300 days and the entry has not liquidated: PSC, through your broker, now, while the 15-days-before-liquidation cutoff is still clear.
• Line 3: the same missed exclusion, on a sister entry that liquidated in May. The PSC door is closed. Protest, inside 180 days of that liquidation date, and the clock is already running.

And if the goods on line 2 were later exported, a drawback claim could reach the eligible duty even after both administrative windows close. One shipment, three lines, three pathways, three deadlines. That is the normal case, not the exotic one.

Why this is per-entry, per-line math

No pathway is chosen per importer, or even per entry. It is chosen per line, by the interaction of the error type, the program, the entry date, and the liquidation date. That is mechanical work: four rules applied to a few dates per line. It is also exactly the kind of work that never gets done by hand across a year of entries, which is how recoverable findings quietly expire. The tariff check tags every flagged line with its pathway and its deadline as part of the report; finding the errors in the first place is covered in the exclusions guide and the rest of the series.