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Customs Protest Filing

Customs protest work that finds the liquidations a client's own documents contradict, drafts Form 19 with a footnote on each statement, and lets the licensed broker file.

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Follow one Form 19 protest from funnel to filing ↓
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The problem

Six relief valve entries reclassified for a test lever, twenty days left

CBP posts liquidations in ACE, mostly on Fridays, and a liquidation at a higher duty than entered starts a clock that nobody at the brokerage owns for every client. Someone sees a bill and forwards it; someone else may log it in a spreadsheet.

Deciding which changes a protest can reach, and which ones the client's drawings and test records contradict, is reading work done by hand. Evidence is requested by email and waited on as the days pass, rulings are searched one at a time, and the justification is written in a word processor before it is keyed into ACE. An entry with good documents can pass its deadline unnoticed.

Built forProtest specialistsLicensed customs brokersBrokerage ownersClient trade compliance leads

The Problem Today

When CBP liquidates at a higher duty, a protest clock starts, and the few entries worth fighting are found by hand.

180 days
to protest a liquidation decision before it becomes final published

Gathered by email, entry by entry

  • Bills
  • Drawings
  • Test files
  • Rulings
  • Deadlines nobody ownsEvery client's liquidations, each on its own count
  • Statements the drawing contradictsA justification that disagrees with the client's own file

The Solution

  1. Liquidations narrowed dailyEach morning, changed entries sorted by whether a protest can reach them
  2. Statements tied to pagesForm 19 drafted with a footnote on each statement
  3. The denial written firstA challenger drafts what the deciding officer would send back
  4. Client approval, then the brokerThe client approves; the licensed broker signs and files in ACE

Built-in controls

  • A licensed broker signs and files each protest
  • Court steps and accelerated disposition stay with counsel
  • A client's typed note is read by staff, never quoted

What You Get

Each protest worth filing is found while the clock still runs, and goes to CBP with every statement resting on a page.

  • Same decision, other clientsEntries across the client base hit by one CBP ruling
  • Routes priced before choosingProtest, further review or accept, with money and time
  • Broker rulings kept as rulesA grouping decision recalled the next time it matters
Features

Customs protest features, from the morning's liquidations to a Form 19

Specialists race the deadlines with them; the broker who holds the license signs and files, and the client's counsel keeps the court decisions. The screens follow six entries of spring-loaded relief valves reclassified after liquidation.

demoBrokerage, clients, supplier, staff, entries, rulings and sums here are sample data, not real records.

  1. 01Protest funnel

    Every liquidated entry narrowed to the protests worth filing, by deadline

    • Each step with its count and fall-out reason. The specialist sees why entries drop out, from the client's own corrections to rates Commerce set that no protest can change.
    • Narrow end grouped by Wednesday deadline. Friday liquidations make day 180 fall on Wednesdays, so the week's protests are planned as one batch.
    • One next protest to start. The nearest undrafted protest is named with its duty and days left, so the morning starts on the right file.
  2. 02Protest room

    Agents read the notice of action and the client's drawings, steered mid-run

    • Each agent shows what it read. Notices of action, bills, drawings, test records and rulings are listed with the passage relied on, one click from the page.
    • Other clients searched on one instruction. Asking for other clients' entries under the same decision adds a step, and what it finds becomes its own draft.
    • Form 19 fills while the agents work. Fields follow the contents CBP's protest rule requires, so the specialist sees at a glance which ones are still empty.
  3. 03Drafted

    Justification drafted statement by statement, a footnote under each

    • Footnote on each statement. The broker and CBP can follow every claim to the drawing, test record, invoice or ruling behind it.
    • Statements edited by the specialist, logged. A changed sentence keeps its old and new wording, so the client sees what moved before approving.
    • A missing record holds the protest. A statement that rests on a record not yet received is flagged, and preparation waits until it is read.
  4. 04Form 19

    CBP Form 19 laid out field by field, entries listed with liquidation dates

    • Entries grouped by product and decision. One protest covers entries that share the party, the merchandise and CBP's decision; a different product goes in its own.
    • Decision protested stated exactly. Tariff number, rate and the notice of action that changed them are written out, so CBP reads exactly which decision is objected to.
    • Drawback declaration confirmed by the client. The client confirms the drawback line when it approves, rather than the brokerage assuming it.
  5. 05Denial draft

    The denial CBP would send, written first and answered paragraph by paragraph

    • Classification, material and grouping attacked. Each argument a deciding officer could use is met with a source while the protest can still change.
    • The drafter's own wording caught. A statement the client's drawing contradicts is reworded and re-cited before anyone signs it.
    • Judgment calls handed to named people. Accelerated disposition goes to counsel and further review to the licensed broker, each citing the regulation that governs it.
  6. 06Client evidence

    Missing test record asked of the client's engineer, field by field

    • Model, serials, set pressure and test date asked. The engineer answers exactly what the protest needs, and the reply is checked against the drawing's tolerance.
    • Sent by the specialist with a reason. Nothing reaches the client until the specialist sends it, with why the record matters written down.
    • Notes outside the fields read by staff. A typed remark from the client goes to the specialist in full and never into a statement.
  7. 07Routes

    Protest, ask for further review, or accept the liquidation, played forward

    • Money back if granted, with interest. The duty increase and the interest billed with it are added up, so the client sees what a protest is worth.
    • Assumptions marked and editable. Overpayment interest and CBP's decision time are labeled assumed, for the specialist to check.
    • Court line kept for counsel. What a denial would start is shown for counsel only, and no route is recommended.
  8. 08Counsel

    Accelerated disposition decided by the client's customs counsel

    • The thirty-day deemed denial laid out. Counsel sees that a request starts a clock toward court before deciding, and the protest is not held for it.
    • Only this client's matters shown. Counsel and the client's trade lead see their own protests, rulings and trail, and no other client's.
    • Working notes never cited. Counsel's note is kept out of every statement, attachment and export, which list it as excluded.
  9. 09Sign and file

    Licensed broker opens Form 19 in full, signs as filer and files in ACE

    • Each step with its signer. Specialist prepares, the client's trade lead approves as second person, and the licensed broker signs as filer.
    • Broker's queue sorted by day 180. Protests waiting for the broker or the client show their day 180, so the broker signs the closest ones first.
    • Nobody signs their own preparation. A protest the broker prepared goes to another licensed broker to sign.

Who works a brokerage's protests from liquidation to filing in ACE

Specialists find and draft, a license holder signs, and the client approves what is said in its name.

Protest specialists

Run the funnel, start and steer the agents, request evidence and prepare protests

  • The protests due soonest, already sorted
  • Form 19 drafted with footnotes
  • Evidence requests answered in fields
Licensed customs brokers

Decide judgment points, sign as filer and file each protest in ACE

  • Form 19 opened in full before signing
  • The client's typed words, exactly as sent
  • Grouping rulings remembered next time
Brokerage owners

Approve rules learned and settings, and set client terms

  • Deadlines across all clients in one view
  • Rules applied only after their signature
  • A protest file kept for each entry
Client trade compliance leads

Approve each protest on their company's entries as second person

  • The full protest before CBP reads it
  • Changed statements marked since last review
  • Only their own company's matters

Eight agents narrow, read and draft, and the licensed broker files

Each works one part of the protest and names who it hands to.

Liquidation watcher

Reads ACE liquidations for every client entry each morning, compares them with the entry summary and starts each clock.

  • Decides no change is wrong
Decision reader

Reads the notice of action, the bill and the change, and sorts out what a protest can reach.

  • Treats no Commerce-set duty rate as protestable
Evidence reader

Reads the client's drawings, test records and invoices and CBP's rulings, quoting the passage relied on.

  • Takes no outside free text as evidence
Client evidence

Writes the client's evidence requests as fields and files, and checks the answers against the drawing.

  • Waits for the specialist to send
Protest drafter

Drafts each Form 19 statement with a footnote, and groups entries by product and decision.

  • Writes no statement without a source
  • Decides no court step
Denial draft

Writes the denial the deciding officer would send, including errors in the agents' own draft.

  • Approves no draft
  • Gives no legal view
Entry finder

Finds entries across all clients liquidated under the same decision, when the specialist asks.

  • Puts no entry into a protest on its own
Outcome rehearsal

Plays protest, further review and accept forward with money and time.

  • Recommends no route
More screens

Fall-out reasons, the day 180 calendar and the engineer's request page

What the specialist, the client's engineer and the owner open around the same protest.

One funnel step, entry by entryThe 893 entries a protest can reach, each with its client, port, change at liquidation, duty change, days left and where it went next.
Day 180, week by weekEvery protest deadline in the next nine weeks on a calendar, with filed, waiting and not drafted protests and holidays marked.
What the client's engineer answersModel, serial range, set pressure, opening pressure, test date and the record file; anything typed in the note goes to a person.
Rules from rulingsA broker's grouping ruling proposed as a rule waits for the owner; rules in force and one rejected show their source and effect.
The protest's trailPeople, agents and outside parties on one trail with reasons; counsel's reasons are privileged and withheld.

demoSample data, from the working solution.

Filing, court steps and further review stay with licensed people

Filing with CBPThe licensed broker opens Form 19 in full, signs as filer and files in ACE; no agent submits anything.
Accelerated disposition and courtCounsel decides with a reason, the client's trade lead confirms, and the broker mails the request.
Further reviewWhether a ruling is close enough to ask for it is the licensed broker's judgment when signing.
What is said in the client's nameThe client's trade lead approves each protest after reading it, and a return clears the signatures.
Rules and settingsA rule learned from a ruling, or a changed alert window, applies only after the owner approves it.

ACE bills, notices of action, client drawings and CBP's own rulings

Where each statement in a protest comes from.

Liquidation status and billsFrom ACE through the customs filing software, for every client entry.
Notices of action and entry summariesCBP Form 29 and the summaries as filed, read for what changed.
Client drawings, specifications, test records and invoicesFrom document management, cited by page.
Client answersStructured requests answered in the client portal, fields and files.
CBP rulings and the HTSUSSearched for the same or similar goods and quoted where relied on.

What brokers ask about customs protest filing

What is a customs protest?

A customs protest is the importer's written objection to a CBP decision, such as a liquidation at a higher duty, filed on Form 19 or electronically in ACE. Here agents find the liquidations worth protesting and draft each one, and the filing is signed by a licensed broker.

How long do you have to protest a liquidation?

A protest is filed within one hundred eighty days of the decision protested. After that the liquidation is final, which is why the funnel sorts the narrow end by day one hundred eighty.

Who can file a CBP protest?

The importer of record or its authorized agent, including the importer's broker or attorney. Here the licensed broker files in the ACE protest module after the client's trade lead approves.

Can one Form 19 protest cover several entries?

Yes, when the protesting party, the category of merchandise and CBP's decision are common to all of them, even across ports. An entry with a different product is moved into its own protest.

Should we ask for accelerated disposition?

That is counsel's decision. If CBP does not act within the deadline after the request, the protest is deemed denied and the time to go to court begins, so the agents lay out the clocks and give no view.

What happens to entries with the same decision at other clients?

When the specialist asks, the entry finder searches all clients for liquidations under the same decision, and each match becomes its own protest draft with its own deadline.

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Bring last month's liquidations
and one client's drawings.

We will narrow your own liquidations to the protests worth filing and draft one Form 19 with you, statement by statement.

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