CBP Form 19: Protest Rules, Deadlines, and ACE Filing

Key Points

• CBP Form 19 (rev 04/24) is the protest form used to contest a CBP decision under 19 U.S.C. 1514, including liquidation, classification, valuation, and rate of duty.
• A CBP Form 19 protest must reach CBP within 180 days after liquidation, and the procedural rules sit in 19 CFR part 174.
• Protests are filed electronically through a protest filer account in the ACE Portal using the ACE Protest module, deployed 2016-08-27, or on paper at the port.
• A protest is a post-liquidation vehicle: it is not a Post Summary Correction and not a 19 U.S.C. 1520(d) claim.
• The most common CBP Form 19 failures are late filing, entries left off the protest, missing supporting documents, and using a protest where a pre-liquidation correction was the right tool.

On this page

1. What CBP Form 19 is
2. At a glance
3. What decisions can be protested on CBP Form 19
4. When is CBP Form 19 filed?
5. How is CBP Form 19 filed in ACE?
6. What belongs in a CBP Form 19 protest package
7. Further review and what happens after a decision
8. Common CBP Form 19 errors and what they cost
9. How CBP Form 19 relates to other CBP forms
10. Frequently asked questions
11. What importers and brokers should do
12. Key references

CBP Form 19, Protest, is the document an importer, its licensed customs broker, or its attorney files to contest a CBP decision under 19 U.S.C. 1514, such as the liquidation of an entry, a tariff classification, an appraised value, or the rate and amount of duties assessed. CBP Form 19 sits at the end of the entry lifecycle, after liquidation, and it is the administrative remedy that must generally be exhausted before a denied claim can be litigated. It is filed either electronically through a protest filer account in the ACE Portal or on paper at the port of entry that made the decision.

The links in this article go to the primary documents: the statute, the regulations in title 19, and CBP's own form and portal pages themselves. Read the source. Information here is current as of September 2026; confirm the current form revision and filing procedure before you file.

At a glance

• Full name: CBP Form 19, Protest (rev 04/24).
• Who prepares or uses it: the importer of record, its customs broker, or its attorney; CBP port and Center personnel review and decide it.
• When in the lifecycle: after liquidation of the entry, within 180 days after liquidation.
• System or channel: the ACE Protest module through a protest filer account in the ACE Portal, deployed 2016-08-27, or paper filing at the port.
• Governing authority: 19 U.S.C. 1514 and 19 CFR part 174.
• Related terms: CBP Form 29, Notice of Action; CBP Form 28, Request for Information; CBP Form 3461, Entry/Immediate Delivery; CBP Form 301, Customs Bond.
• Not to be confused with: a Post Summary Correction, which is a pre-liquidation correction, or a claim under 19 U.S.C. 1520(d).

What decisions can be protested on CBP Form 19

CBP Form 19 reaches the categories of CBP decisions that Congress made protestable in 19 U.S.C. 1514, which include the liquidation or reliquidation of an entry and the classification, appraised value, rate, and amount of duties chargeable on the merchandise. In practice that covers the outcomes importers argue about most: the Center classified goods under a heading the importer disputes, rejected a claimed duty preference, added an assist or royalty to transaction value, or liquidated at a rate the importer believes was wrong. Where a decision falls outside the statute, CBP Form 19 is not the vehicle, and the filer should confirm the correct remedy in the current regulation or with CBP before spending time on a protest that will be rejected as non-protestable.

CBP Form 19 is also an all-grounds document in one important sense: 19 U.S.C. 1514(c)(3) governs the time in which a protest must be filed, and the protest itself should set out every legal and factual ground the filer intends to rely on. Grounds not raised are grounds the reviewing officer never sees.

When is CBP Form 19 filed?

CBP Form 19 must reach CBP within 180 days after liquidation of the entry being contested. That is a receipt deadline, not a postmark practice question to be guessed at: build the calendar backward from the liquidation date shown in ACE, not from the date the importer received a bill or noticed a problem. A protest that arrives after the window closes is normally rejected as untimely no matter how strong the classification or valuation argument behind it is.

Because the clock runs from liquidation, CBP Form 19 is inherently a post-liquidation tool. If the entry has not yet liquidated and the importer wants to fix its own entry summary data, the correct vehicle is a Post Summary Correction rather than a protest. Filing the wrong one wastes the window.

How is CBP Form 19 filed in ACE?

CBP Form 19 is filed electronically through the ACE Protest module, which CBP deployed on 2016-08-27, using a protest filer account in the ACE Portal, or on paper at the port. Electronic filing gives the filer a submission record, a protest number, and visibility into status, which matters when a decision is close to the deadline or when several entries are consolidated into one protest. Before the first filing, the importer, broker, or attorney needs the protest filer account provisioned; confirm current account setup steps on CBP's ACE pages or with the client representative, because portal account roles change over time.

Paper filing at the port remains available. Whichever channel is used, keep proof of what was filed and when, together with the list of entry numbers included.

What belongs in a CBP Form 19 protest package

A CBP Form 19 protest package should identify every entry being protested, state the decision objected to, set out the grounds, and attach the documents that prove the point. Typical support includes the entry summary and commercial invoice, product literature or laboratory results for a classification dispute, purchase and payment records for a valuation dispute, and any prior CBP ruling or correspondence the importer relies on. If CBP previously issued a CBP Form 28, Request for Information, which is CBP's written request for documents or facts needed to appraise or classify entered goods, or a CBP Form 29, Notice of Action, which is CBP's notice that it proposes or has taken action on an entry, include that exchange so the reviewer sees the full record.

Assertions without documents are the weakest protests CBP receives. A one paragraph disagreement with a rate advance rarely moves a reviewer; a short, organized package with exhibits does.

Further review and what happens after a decision

A CBP Form 19 protest may include a request for further review, which asks that the matter be considered above the deciding office rather than by the port or Center alone. The criteria and the mechanics are in 19 CFR part 174; confirm the current requirements there before checking the box, because a request that does not meet the criteria can be denied while the protest itself is decided on the merits. If CBP denies the protest, the denial can be litigated, and the filer should confirm the applicable litigation deadline in the current statute and rules rather than assuming one.

Common CBP Form 19 errors and what they cost

Most CBP Form 19 problems are administrative rather than substantive. The recurring ones:

• Late filing. Missing the 180 days after liquidation ends the administrative remedy for that entry.
• Entries omitted. A protest covering three of eight affected entries leaves the other five liquidated and final.
• No supporting documents. The reviewer has no basis to reverse the decision.
• Wrong vehicle. A protest filed where a pre-liquidation Post Summary Correction was the right tool, or where the claim is really a 19 U.S.C. 1520(d) claim.
• Vague grounds. A protest that does not say which heading, which valuation method, or which authority supports the importer's position.

How CBP Form 19 relates to other CBP forms

CBP Form 19 sits at the opposite end of the entry lifecycle from the release and entry documents brokers handle daily. CBP Form 3461, Entry/Immediate Delivery, the release request asking CBP to release imported cargo from custody before the entry summary and now transmitted as ACE Cargo Release data, starts the cycle; CBP Form 19 closes it. Obligations secured by CBP Form 301, Customs Bond, the surety bond, single transaction or continuous, securing duties, taxes, fees and compliance obligations to CBP, remain in play while a protest is pending, so coordinate with the surety when protested amounts are large. Identity data filed on CBP Form 5106, Create/Update Importer Identity Form, which registers or updates an importer of record or ultimate consignee identity in ACE, should be current so the protesting party matches the importer of record of record.

Protests often grow out of earlier correspondence. Read CBP Form 28 and CBP Form 29 alongside this entry, since the response to those notices frequently determines whether a CBP Form 19 protest is ever needed.

Other forms in the cluster do not lead to CBP Form 19 protests as often but share the same lifecycle: CBP Form 7512, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit, the electronic in-bond application for moving unentered goods under bond; CBP Form 214, Application for Foreign-Trade Zone Admission and/or Status Designation, which admits merchandise into an FTZ and elects zone status; CBP Form 216, Application for Foreign-Trade Zone Activity Permit, which requests CBP approval to manipulate, manufacture, exhibit or destroy merchandise inside a foreign-trade zone; CBP Form 7551, Drawback Entry, the paper drawback claim abolished with TFTEA drawback and now filed electronically in ACE; and CBP Form 7552, Delivery Certificate for Purposes of Drawback, also abolished under TFTEA and replaced by transfer records.

Frequently asked questions

Is CBP Form 19 the same as a Post Summary Correction?

No. CBP Form 19 is a post-liquidation protest of a CBP decision under 19 U.S.C. 1514, while a Post Summary Correction is a pre-liquidation correction of the importer's own entry summary data. If the entry has not liquidated, a protest is premature.

Who can file CBP Form 19?

CBP Form 19 is filed by the importer of record or by a party authorized to act for it, typically the licensed customs broker or an attorney. Confirm the current authorization and power of attorney requirements in 19 CFR part 174 before filing on someone else's behalf.

Can one CBP Form 19 cover multiple entries?

Yes, a single CBP Form 19 protest can cover multiple entries where the regulations permit, which is common when the same classification or valuation issue repeats. List every entry number; entries left off are not protected by the protest.

What happens if CBP denies a CBP Form 19 protest?

A denial of a CBP Form 19 protest can be litigated. Confirm the applicable court deadline and procedure in the current statute and rules before relying on any date.

What importers and brokers should do

• Monitor liquidation dates in ACE and diary the 180 days after liquidation deadline for every entry with a disputed classification, value, or rate.
• Provision a protest filer account in the ACE Portal before you need it, so a deadline is never lost to account setup.
• Decide early whether the issue is a pre-liquidation correction or a CBP Form 19 protest, and document the reasoning.
• Assemble the exhibits, prior CBP Form 28 and CBP Form 29 correspondence, and legal grounds into one package before filing rather than promising documents later.

Key references

• 19 U.S.C. 1514: the statute defining which CBP decisions are final unless protested, including 19 U.S.C. 1514(c)(3) on the time for filing.
• 19 CFR part 174: the protest regulations, including further review.
• CBP forms library: current revision of CBP Form 19, Protest (rev 04/24).
• CBP ACE pages: ACE Portal accounts and the ACE Protest module, deployed 2016-08-27.
• Harmonized Tariff Schedule of the United States: the classification text underlying most protest arguments.