The IEEPA refund opportunity is real, but it is not permanent. Eligibility is deadline-driven, and importers who treat it as something to get to eventually often find that some of their recoverable duty has quietly expired.
How the deadline works
Refund windows are tied to when your entries liquidate with CBP. Liquidation is Customs' final calculation of the duties owed on an entry, and it starts a clock. Once that window closes on a given entry, the duty attached to it is no longer recoverable.
Why it slips away
Because entries liquidate on a rolling basis, your recoverable duty does not expire all at once. It erodes month by month, entry by entry. That makes delay deceptively expensive: you do not lose everything on a single date, so it never feels urgent, and then a meaningful share is simply gone.
The setup delay problem
There is a second timing trap. Filing requires an active ACE Portal account, and setting one up takes time. Importers who wait until they are ready to file, then discover they need to create an ACE account, file Form 5106, and enroll in ACH, can lose weeks that eligible entries did not have to spare.
What to do about it
The fix is simple: start now, even if you are not certain you qualify. A free eligibility check takes about a minute, and if you need to get ACE-ready, we send you the setup instructions so that step does not stall the rest. The worst outcome is not a claim that gets denied. It is a claim that never got filed in time.