19 U.S.C. § 1501

Voluntary reliquidations by U.S. Customs and Border Protection

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A liquidation made in accordance with section 1500 or 1504 of this title or any reliquidation thereof made in accordance with this section may be reliquidated in any respect by U.S. Customs and Border Protection, notwithstanding the filing of a protest, within ninety days from the date of the original liquidation. Notice of such reliquidation shall be given or transmitted in the manner prescribed with respect to original liquidations under section 1500(e) of this title.

Notes of Decisions
Cited in 203 cases (11 in the last 5 years), 1934–2026 · leading case: Norsk Hydro Canada, Inc. v. United States, & U.S. Magnesium LLC, 472 F.3d 1347 (Fed. Cir. 2006).
Norsk Hydro Canada, Inc. v. United States, & U.S. Magnesium LLC, 472 F.3d 1347 (Fed. Cir. 2006). · cites it 2× “19 U.S.C. § 1501 . At the time this action accrued, a party also could request Customs to reli-quidate an entry under 19 U.”
United States v. Great Am. Ins. Co. of New York, 229 F. Supp. 3d 1306 (Ct. Intl. Trade 2017). · cites it 13× “The court denied the motion to dismiss, finding that Customs has statutory authority to reliquidate deemed liquidations within 90 days of transmitting notice of the deemed liquidation to importers pursuant to 19 U.S.C. § 1501 , 19 and the complaint adequately alleged facts…”
Jt. Anti-Fascist Refugee Comm. v. McGrath, 341 U.S. 123 (1951). · cites it 2× “187 , as amended, 19 U. S. C. § 1501 ; see Freund, Administrative Powers over Persons and Property, 163.”
Aspects Furniture Int'l, Inc. v. United States, 2020 CIT 120 (Ct. Intl. Trade 2020). · cites it 7× “An entry that liquidated by operation of law may, however, be voluntarily reliquidated by CBP pursuant to 19 U.S.C. § 1501 within the time period provided Court No.”
Thyssenkrupp Steel N. Am., Inc. v. United States, 886 F.3d 1215 (Fed. Cir. 2018). · cites it 2× “See also 19 U.S.C. § 1501 (addressing reliquidation); 19 C.”
New Zealand Lamb Co., Inc. v. United States, 40 F.3d 377 (Fed. Cir. 1994). · cites it 2× “This accords with 19 U.S.C. § 1501 (1988), which provides that "[a] liquidation .”
United States v. Am. Home Assurance Co., 789 F.3d 1313 (Fed. Cir. 2015). · cites it 2× “In the same breath, though, it urges that because the reliquida-tions occurred more than ninety days after the June 2004 liquidations, they were nevertheless invalid under 19 U.S.C. § 1501 for purposes of conferring liability.”
United States v. Great Am. Ins. Co. of N.Y., 2015 CIT 129 (Ct. Intl. Trade 2015). · cites it 13× “Parties’ Contentions GAIC argues that Customs lacked the authority to reliquidate the entry at issue in this case because the relevant statute, 19 U.S.C. § 1501 , does not permit Customs to reliquidate entries that are liquidated by operation of law.”
Target Corp. v. United States, 134 F.4th 1307 (Fed. Cir. 2025). · cites it 7× “Under 19 U.S.C. § 1501 , Customs could have voluntar- ily reliquidated those entries “within ninety days from the date of the original liquidation.”
SSAB North Am. Div. v. United States Bureau of Customs & Border Prot., 571 F. Supp. 2d 1347 (Ct. Intl. Trade 2008). · cites it 2× “Defendant-Intervenors contend that Plaintiffs do have a remedy under 19 U.S.C. § 1501 to correct an erroneous liquidation.”
Perfectus Aluminum, Inc. v. United States, 2019 CIT 79 (Ct. Intl. Trade 2019). · cites it 3× “18 Voluntary reliquidation by Customs is governed by 19 U.S.C. § 1501 , and Customs is time-barred by the relevant version of the statute from reliquidating those entries to include the assessment of antidumping and countervailing duties.”
AK Steel Corp. v. United States, 281 F. Supp. 2d 1318 (Ct. Intl. Trade 2003). “3 The Justice Department’s suggestion to rectify the problem was for Customs to “voluntarily reliquidate” the nine liquidations pursuant to its authority under 19 U.S.C. § 1501 , on the ground that the liquidations were not yet “final,” at a higher rate than the rate at which…”
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