19 U.S.C. § 1520 provides reliquidation in limited circumstances when the protest window has closed. § 1520(c) covers clerical or factual errors discovered within 1 year of liquidation. § 1520(d) covers FTA preference claims discovered within 1 year. Narrow eligibility; success rates lower than protests.
This guide covers Section 1520 Reliquidation. Refund and recovery work spans multiple statutes and mechanisms – drawback, CAPE refunds, PSCs, protests, reliquidation under § 1520.
For SMB importers, the practical implementation depends on volume, sector, and operational structure.
§ 1520(c) clerical errors
Clerical or factual errors in liquidation. Within 1 year. Limited to administrative or technical errors.
§ 1520(d) FTA preferences
Missed USMCA / FTA preference claims discoverable within 1 year of liquidation. Useful for retroactive claim of preference where Certificate was available but not used.
Eligibility test
Narrower than protest. Substantive disagreements not covered. Strictly clerical or specific FTA-related.
Success rates
Lower than protests. Best when narrowly framed around actual clerical error or specific FTA scenario.
Frequently asked questions
When is this most relevant?
For SMB importers facing audit, refund opportunity, or compliance gap remediation.
What documentation matters?
CBP forms, supporting records, supplier certificates, and BOM analysis as applicable.
What is the timeline?
Simple matters 2-4 weeks; complex audits or refund filings 3-12 months.
What does this cost?
Project scope $5,000-$45,000 depending on complexity. Refund work often on contingency.
How do I begin?
Book a 15-minute scoping call. We confirm fit before any engagement.
Get started
Run a refund opportunity audit on your import history. Free preliminary estimate.