Protest (CBP Form 19)

A Protest is a formal administrative challenge filed by an importer of record, surety, or other interested party against a CBP decision on a liquidated entry. Authorized by 19 U.S.C. § 1514, protests are the primary mechanism for contesting CBP's classification, valuation, country of origin, marking, or duty determinations.

Filing deadlines.

• 180 days from the date of liquidation for most protests — this is the firm statutory deadline; missing it is fatal
• Petitions for delay in liquidation (under 19 U.S.C. § 1520) may extend the practical window for certain issues
• Protests against denied drawback claims are filed under separate procedures

Protestable decisions (19 U.S.C. § 1514(a)):

• Classification (HTS code)
• Rate of duty
• Charges or exactions
• All decisions excluding merchandise from entry or delivery
• Liquidation or reliquidation
• Refusal to liquidate
• Refusal to reliquidate
• Refusal to allow a drawback claim
• Decisions on country of origin marking

Filing procedure:

1. File electronically through ACE (preferred) or on CBP Form 19 (paper)
2. Identify each protested decision and the legal grounds
3. Include supporting documentation (invoices, ruling citations, expert reports)
4. Request accelerated disposition if desired — forces CBP to rule within 30 days or the protest is deemed denied

CBP review. CBP must decide most protests within two years of filing. If denied, the importer may file a summons with the U.S. Court of International Trade (CIT) within 180 days of the denial.

Protests are the foundational due process mechanism in U.S. customs law. Importers should treat the 180-day deadline as inviolable — there is no general extension provision.