Customs Protest Filing: How to File CBP Form 19 (2026 Guide)

A customs protest is filed under 19 U.S.C. § 1514 to challenge CBP’s liquidation of an entry – duty assessment, classification, valuation, country of origin, or denial of a preference. Filing deadline: 180 days from liquidation. Filed electronically through ACE on CBP Form 19 (or its electronic equivalent). Decisions typically come in 60-180 days; denials can be appealed to the U.S. Court of International Trade.

After an entry liquidates, the Post Summary Correction window closes. To recover overpaid duty or contest a CBP determination after liquidation, importers file a protest under 19 U.S.C. § 1514. The window is 180 days from liquidation date – short, hard, and unforgiving.

This guide walks through what a protest is, when to file one, and how to structure the filing to maximize the chance of approval.

What a protest can and cannot challenge

Section 1514 lists the seven categories of CBP determinations that can be protested:

1. Appraised value of merchandise.
2. Classification, rate, or amount of duty.
3. Charges, exactions, or fees.
4. Exclusion of merchandise from entry.
5. Liquidation or reliquidation of an entry.
6. Refusal to pay a claim for drawback.
7. Refusal to reliquidate an entry under § 1520(c).

The 180-day deadline

Protests must be filed within 180 days of the date of liquidation. The clock starts on the liquidation date, not the entry date or the duty payment date. Late filings are jurisdictionally barred – CBP cannot extend or accept them.

For multiple entries with the same issue, you can file a “blanket protest” under 19 CFR 174 covering up to 100 entries on a single filing – but each entry’s 180-day window must still be open.

How to file a protest step by step

• Identify the protest issue and the specific entry (or entries) affected.
• Confirm liquidation date(s) and that you are within 180 days.
• Compile supporting documentation: entry summaries, commercial invoices, bills of lading, classification analyses, country-of-origin documentation, valuation worksheets.
• Prepare the protest content: clear statement of the issue, the determination being protested, the legal basis for the challenge (citations to statutes, regulations, rulings, court decisions).
• File electronically through ACE on Form 19 (or paper Form 19, though electronic is now standard).
• CBP reviews. Decisions typically come in 60-180 days. Filings can be denied, granted in full, or granted in part.
• If denied: appeal to the U.S. Court of International Trade within 180 days of denial. Filing in CIT requires payment of denied duties first.

What makes a protest succeed or fail

1. Succeed: clear legal argument citing controlling authority (CBP rulings, court decisions, statutory text). Strong documentation. Reasonable scope.
2. Fail: vague claim of “wrong classification” without alternative classification proposed. Missing documentation. Filed after the 180-day window. Issue not within the seven protestable categories.

Protest vs. PSC vs. CIT lawsuit – when to use which

PSC (before liquidation)

Routine correction. No deadline pressure. Free to file. Use when entry has not yet liquidated.

Protest (within 180 days of liquidation)

Standard challenge to liquidation. Filed at CBP. Free to file. Decision in 60-180 days. Most disputes resolve here.

Court of International Trade lawsuit

After protest denial. 180 days from denial to file. Requires duty payment first. CIT decisions are appealable to the Federal Circuit. Reserved for high-value disputes (>$50k typically).

Frequently asked questions

How long do I have to file a customs protest?

180 days from the date of liquidation. The clock cannot be extended.

Do I need an attorney to file a protest?

Not required, but recommended for complex protests or claims above ~$25k. Customs consultants can also file on the importer’s behalf if authorized.

What is the difference between a PSC and a protest?

PSC: filed before liquidation, no deadline beyond liquidation date, no formal hearing. Protest: filed after liquidation, hard 180-day deadline, formal challenge.

What happens if my protest is denied?

You can appeal to the U.S. Court of International Trade within 180 days of denial. CIT filing requires payment of the denied duties first (the duties become recoverable if you win at CIT).

Can I file a protest on multiple entries at once?

Yes. Blanket protests can cover up to 100 entries on a single filing, provided each entry’s 180-day window is still open and the protest issues are common across entries.