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October 2025, question 41

Entry / Entry Summary · Liquidation, reliquidation and protests

Importer Sunny Solar Panels filed an entry for a shipment that arrived in the Los Angeles/Long Beach seaport on March 1, 2020. Sunny Solar Panels filed an entry summary on March 3, 2020, and tendered all duties, taxes, and fees owed. The merchandise was released from U.S. Customs and Border Protection (CBP) custody on March 3, 2020. CBP liquidated the entry on January 22, 2021. Upon reviewing the liquidation, Sunny Solar Panels realized that due to a clerical error they overpaid harbor maintenance fees. What is the deadline for Sunny Solar Panels to file a protest?

  1. Within 90 days of January 22, 2021
  2. Within 180 days of January 22, 2021
  3. Within 365 days of March 1, 2020
  4. Within 180 days of March 3, 2020
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CBP's answer: B. B: Within 180 days of January 22, 2021

Section 174.12(e) gives 180 days to protest for entries made on or after December 18, 2004, counted from the listed events, including the date of liquidation (here January 22, 2021). The 90-day period is only for entries before December 18, 2004, and the clock does not run from entry or release.

within 180 days of a decision relating to an entry made on or after December 18, 2004 19 CFR 174.12(e)
The date of notice of liquidation or reliquidation, or the date of liquidation or reliquidation 19 CFR 174.12(e)(1)

Search for: within 180 days of a decision relating to an entry made on or after December 18, 2004

CBP's key cites: 19 CFR 174.12(e)(1)

Question and key from CBP's October 2025 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).