Ouli Refund / Guides

Comparison · Refund routes

CAPE or protest, side by side.

CAPE is a purpose-built administrative process for the IEEPA refund, filed as a CSV of entry numbers through the ACE Portal, and it is irrevocable once accepted. A protest under 19 U.S.C. § 1514 is the general mechanism for contesting a CBP decision, filed on CBP Form 19 after an entry liquidates and within 180 days of that liquidation. They are not alternatives a filer picks freely: which applies depends on the entry's status and class, and that determination belongs to a licensed customs broker or attorney.

PUBLISHED 2026-08-31 · FIGURES FROM CBP COURT FILINGS AND PUBLIC RECORDS, AS OF JULY 2026

Filed by
Both: the importer of record or the licensed broker who filed the entry summaries. A protest may also be filed by the importer's attorney.
Filed how
CAPE: CSV upload via the CAPE tab in the ACE Portal. Protest: CBP Form 19, via the ACE Protest Module or on paper.
Timing
CAPE: opened in phases from 20 April 2026. Protest: only after liquidation, within 180 days of the notice.
Reversible?
CAPE: no — an accepted declaration cannot be withdrawn or amended. Protest: a separate submission with its own record.
If you miss it
Protest: the 180-day lapse permanently bars the administrative challenge for that entry.
Payment
CAPE: generally 60–90 days after acceptance, including about 45 days of CBP review.

Why irrevocability changes the work

In ordinary customs practice, a filing error is usually correctable. CAPE is not built that way: once CBP accepts a declaration, it stands. A declaration assembled from entry data that disagrees with the original 7501 at the line level — a different HTS code, a different value, a different quantity — is rejected as a whole, and a single bad line does it.

That inverts the usual economics of checking. Reconciling every entry against its original 7501 before filing stops being diligence and starts being the job. It is the reason a broker's CAPE desk spends more time on comparison than on submission.

Why the protest clock is per entry

A protest contests a decision, and for these purposes the decision is liquidation. So the window opens when an entry liquidates and closes 180 days later, entry by entry. There is no single national deadline, and no date that applies to a whole book of imports.

For an importer with hundreds or thousands of entries, this is a monitoring problem rather than a filing problem: the question is not "when is the deadline" but "which of these entries is closest to lapsing this week". That is what Ouli Refund's Deadline Monitor tracks, and what the public calculator does for one entry at a time.

What neither route fixes

Both routes assume the refund, once granted, can actually be paid. Two things independent of route stop that: missing ACH banking details on the ACE Portal account, and offsets applied under 19 CFR 24.72(b) against other debts owed to CBP.

A separate open question sits above both: the government's appeal contends that refunds on finally-liquidated entries are owed only to the importers who brought suit. Until that is resolved, entries in that category carry a different risk profile — which is exactly the kind of judgement that belongs with counsel, not with software.

Where we stand

Software, not legal advice.

Which route applies to a specific entry — or whether either does — is a determination for your licensed customs broker or attorney. This page compares two public procedures; it does not assess your entries.

Oulution is not a law firm and not a customs brokerage. Nothing on this page is legal, customs or tax advice, and no attorney-client relationship is formed by reading it.

Your entries already know the answer.

Paste an ACE export and get every entry's paths, amounts and deadlines in one session — with the reasoning shown all the way through.

Start free scan → Free deadline calculator

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