ACE Protest Module: Filing and Tracking CBP Protests Explained

Key Points

• The ACE protest module is where importers, brokers and attorneys file, amend and track protests, the electronic CBP Form 19, under 19 U.S.C. 1514 and 19 CFR part 174.
• A protest must be filed within 180 days after liquidation or the date of the protestable decision, and that deadline discipline sits entirely with the filer.
• Filers can request accelerated disposition under 19 CFR 174.22 or further review under 19 CFR 174.23 to 174.26 when opening the protest.
• CBP's decision (allowed, denied or allowed in part) posts in the module and drives any reliquidation and refund.
• The ACE protest module is not a post summary correction (PSC), not the CAPE refund application and not a 1520(d) claim.

On this page

1. At a glance
2. What is the ACE protest module and where does it come from?
3. Who files in the ACE protest module, and when?
4. How does a protest move through the ACE protest module?
5. Common ACE protest module errors
6. How the ACE protest module relates to other ACE functions
7. Frequently asked questions
8. What importers and brokers should do
9. Key references

The ACE protest module is the function in the ACE Secure Data Portal through which importers, customs brokers and trade attorneys file, amend and track protests (the electronic CBP Form 19) against protestable CBP decisions, and through which CBP records its decisions. It sits at the back end of the entry lifecycle, after liquidation or another protestable decision, and the outcome posted there drives reliquidation and refunds.

This entry reflects the workflow as of October 2026. The links in this article go to the primary documents: the statute, the regulations and the official CBP pages themselves. Read the source.

At a glance

• Full name: ACE Protest module, ACE Secure Data Portal
• Who prepares or uses it: Importers, licensed customs brokers and trade attorneys holding a protest filer account; CBP Centers process and decide
• When in the lifecycle: After liquidation or another protestable decision, within 180 days
• System or channel: ACE Secure Data Portal (electronic CBP Form 19)
• Governing authority: 19 U.S.C. 1514 and 19 CFR part 174
• Related terms: ACE Reports, ACE reconciliation, DIS, proxy TAO, ACE AD/CVD case management

What is the ACE protest module and where does it come from?

The ACE protest module is the electronic home of the CBP Form 19 protest, the administrative remedy that 19 U.S.C. 1514 gives a party that disagrees with certain CBP decisions. The statute defines which decisions are protestable, such as liquidation and the classification and duty assessments that flow into it, and makes those decisions final unless a timely protest is filed. 19 CFR part 174 supplies the procedure: who may file, what a protest must contain, time limits, amendments, accelerated disposition and further review.

The module replaces paper handling with a structured record. Each protest carries its entries, the decision protested, the grounds and supporting attachments, and CBP's disposition is recorded against the same record, so filer and Center work from one case file.

Who files in the ACE protest module, and when?

The ACE protest module is used by the importer of record, its licensed customs broker, or its attorney, each working through a protest filer account in the ACE Secure Data Portal. Who may protest on whose behalf is governed by 19 CFR part 174; confirm in the current regulation that the filer qualifies for the specific importer and entries before filing.

The 180-day window

A protest must be filed within 180 days after liquidation or the date of the protestable decision. The module does not manage that clock for you. Brokers and importers should calendar each liquidation date and each decision date as soon as it is known, and treat the window as a hard stop.

Account access

Access to the module is controlled through ACE account permissions. A Trade Account Owner, or a proxy TAO (ACE Trade Account Owner proxy, the user the owner designates to manage users and permissions), grants protest access to the right staff. A proxy TAO is an administrative role, not a power of attorney and not a broker role.

How does a protest move through the ACE protest module?

A protest in the ACE protest module follows a consistent path from filing to decision.

1. Open the protest. The filer creates the protest in the portal and identifies the importer.
2. Name the entries. List every entry the protest covers; anything left off is not protested.
3. State the decision and grounds. Identify the decision protested and set out the legal and factual grounds.
4. Attach support. Upload invoices, technical literature, rulings and other evidence.
5. Request special handling if wanted. Ask for accelerated disposition under 19 CFR 174.22 or further review under 19 CFR 174.23 to 174.26, meeting the criteria in those sections.
6. CBP decides. The responsible Center processes the protest in the module and posts the decision: allowed, denied, or allowed in part.
7. Reliquidation and refund. An allowed or partially allowed protest drives reliquidation and any refund.

This article does not state processing times; check status in the module and confirm expectations with the Center or your broker. Amendments are permitted under 19 CFR part 174 within the limits it sets; confirm the conditions there.

Common ACE protest module errors

Most failures in the ACE protest module are procedural, and procedural failures usually cannot be cured once the window closes.

• Missing the window. A protest filed after 180 days is untimely and the decision stands.
• Protesting an unliquidated entry. If there is no liquidation or other protestable decision yet, there is nothing to protest; the right tool may be a PSC instead.
• Omitting entries. Entries not named are not covered.
• Wrong importer number. Filing under the wrong importer of record misdirects the protest.
• No follow-up on a denial. A denial posted in the module carries its own next steps; confirm options and deadlines in 19 U.S.C. 1514 and with counsel promptly.

How the ACE protest module relates to other ACE functions

The ACE protest module draws on data created elsewhere in ACE, and knowing those sources prevents both missed entries and wrong remedies.

Finding entries and dates

ACE Reports is where most filers identify liquidated entries and dates. ACE Reports Modernized (the rebuilt ACE Reports platform replacing the legacy tool, with the same trade data) and the ACE Reports data dictionary (CBP's reference defining each report field, its source and meaning) help confirm exactly which date a field represents. Before ACE Reports, importers relied on ITRAC (Importer Trade Activity data obtained from CBP under the Freedom of Information Act) to audit broker filings.

Upstream transactions

Data feeding a protestable decision may originate in ACE Cargo Release (the release transaction succeeding the paper CBP Form 3461), ACE in-bond (the electronic in-bond system for moving unentered merchandise under bond), or ACE truck eManifest (the electronic truck manifest carriers transmit before land border arrival). None of these is a protest, but their records can matter as evidence. Antidumping and countervailing duty data come from ACE AD/CVD case management, the ACE function publishing case numbers, rates and liquidation instructions; check those instructions before deciding what is protestable.

Documents and other remedies

DIS (Document Image System, the ACE channel for entry-related images and documents) is separate from protest attachments; confirm with CBP which channel a given protest document belongs in. ACE reconciliation (entry type 09, flagging entry summaries for later reconciliation of value, classification, 9802 or FTA issues) handles known undeterminable items and is not a protest. A PSC corrects an unliquidated entry summary, CAPE is a separate refund application, and a 1520(d) claim is a distinct remedy.

Frequently asked questions

What is the deadline for filing in the ACE protest module?

A protest in the ACE protest module must be filed within 180 days after liquidation or the date of the protestable decision, as set by 19 U.S.C. 1514 and 19 CFR part 174.

Can I use the ACE protest module before an entry liquidates?

Generally the ACE protest module is for liquidated entries or other protestable decisions; protesting an unliquidated entry is a common error, and corrections before liquidation are usually handled by PSC.

How do I request further review in the ACE protest module?

The ACE protest module lets the filer request further review when opening the protest, subject to the criteria in 19 CFR 174.23 to 174.26.

Where does the decision appear?

CBP posts the decision, allowed, denied or allowed in part, in the ACE protest module, and that decision drives reliquidation and any refund.

What importers and brokers should do

• Calendar the 180-day window for every liquidation and protestable decision using ACE Reports data.
• Have the TAO or proxy TAO confirm protest filer access for the right users and importer numbers.
• Before filing, reconcile the entry list against ACE Reports so no entry is omitted.
• Monitor the module after filing and act promptly on any denial.

Key references

• 19 U.S.C. 1514: the statute defining protestable decisions and protest time limits.
• 19 CFR part 174: CBP's protest regulations.
• 19 CFR 174.22: accelerated disposition of protests.
• 19 CFR 174.23 to 174.26: further review of protests.
• CBP Forms: CBP's forms page, including CBP Form 19.
• CBP ACE and automated systems: CBP's landing page for ACE and the Secure Data Portal.