Where To Submit PSA During Tariffs: Trade Compliance Submission Paths

If you import trading cards, memorabilia, or display gear like we do at CardChasers, tariff changes can flip your landed costs overnight. When rates shift, or when you realize a better duty treatment applies, you need to correct entries and, ideally, get money back fast. Here's the catch: many teams say "PSA" when they actually mean different things depending on the country and timing.

This guide breaks down where to submit "PSA" during tariffs across the U.S., Canada, EU, UK, and key Asia-Pacific hubs, plus the documents, deadlines, and decision points that keep you compliant and audit-ready. We'll use practical examples that resonate with the collectibles world (because yes, we live this every day), but the workflows apply to any importer.

If you landed here from our hobby side and were actually looking for live-stream action, you'll feel at home on our card breaks page, our online store, or our grading services. But if you need to figure out PSC vs protest vs post-release adjustments, you're in the right place.

Start With Definitions: PSA Versus PSC, Protest, And Post-Entry Adjustments

When Companies Say "PSA" But Mean "PSC" In The US

In U.S. customs speak, there's no official form called "PSA." What most compliance teams mean by "PSA" is one of the following:

  • Post Summary Correction (PSC): Filed in ACE to fix a summary before liquidation, think classification, value, origin, Section 301/232 exclusion, or even changing the importer of record number. PSCs are the modern replacement for the old Post Entry Amendment (PEA).

  • Protest: Filed after liquidation (when CBP finalizes the entry) to challenge a decision or claim a refund, including belated use of an exclusion or valuation change. This is done in the ACE Protest Module.

  • Post-entry adjustments: A catch-all way people describe corrections outside the initial filing window, usually meaning PSC if pre‑liquidation, protest if post‑liquidation.

If your team says "submit a PSA," ask two questions: Has the entry liquidated? And do we have documentary proof (invoices, rulings, exclusion ID) to support the change? The answers determine whether you go PSC or protest.

Equivalent Terms In Canada, EU, And Asia

  • Canada (CBSA): Under CARM, you file a CAD adjustment (previously B2). Officially it's a Request for Adjustment (RFA) to correct a Commercial Accounting Declaration (CAD). Protests are appeals of CBSA decisions (re-determinations), and drawback/remission programs handle refunds in specific scenarios.

  • European Union: Post-clearance amendment or invalidation in national systems, plus Repayment/Remission under the Union Customs Code (UCC, Articles 116–120). Duty suspension/TRQs are separate policy tools.

  • United Kingdom: Post-clearance amendment (PCA) via the Customs Declaration Service (CDS): repayment/remission via a C285 claim in CDS.

  • China: Post-clearance modification/rectification via the China International Trade Single Window: duty refund applications through Customs after audit.

  • Japan: Post-importation corrections via NACCS: duty/tax refunds through customs under applicable provisions.

  • Singapore: TradeNet amendment permits and formal refund applications (duty remission/exemption via schemes, repayment for overpayments).

Different names, same logic: pre‑finalization corrections vs post‑finalization challenges and refunds.

United States: Where And How To Submit Corrections And Refunds

Post Summary Correction (ACE Portal Or ABI)

  • Where to submit: In the ACE Secure Data Portal or via your broker's ABI software.

  • When to use: Before liquidation. Correct HTS, value, origin, FTA claim, additional duties (e.g., Section 301/232), and even add missing lines. You can also use PSC to claim a granted exclusion before liquidation.

  • Timing: PSC can be filed any time from the date the entry summary is in CBP's system up to 15 days before the scheduled liquidation date (liquidation is typically 314 days after entry, but CBP can extend/suspend).

  • Tips:

  • If a Section 301 exclusion becomes retroactive and applies to your entry, file a PSC to recover those duties pre‑liquidation.

  • Watch for FDA/USDA/Partner Government Agency flags, some changes trigger new PGA data.

  • Maintain a clear audit trail: original data, reason for change, calculations, and documentary support.

Protests For Liquidated Entries (ACE Protest Module)

  • Where to submit: ACE Protest Module (you or your broker/attorney).

  • When to use: After liquidation to challenge CBP's decision, classification, valuation, origin, exclusions, or denied PSC.

  • Deadline: 180 days from the date of liquidation. Miss it and you'll likely lose the refund.

  • Strategy:

  • Attach precise legal basis: HTS notes, rulings (HQ or NY), Federal Register exclusion notices, binding rulings, or court decisions.

  • Use "application for further review" (AFR) if your issue is novel or inconsistent with CBP decisions.

  • Expect months for adjudication. Track by protest number and respond promptly to any CBP requests.

Section 301/232 Exclusion Refunds (PSC Versus Protest)

  • If the entry is still open: Use PSC to claim the exclusion and remove/add the appropriate Chapter 99 number.

  • If the entry has liquidated: File a protest: include the exclusion number/evidence and show the product fits the scope.

  • Retroactivity: Many 301 exclusions, when reinstated, allow refunds on eligible entries within a defined window. Read the specific Federal Register notice for scope, documentation, and time limits.

Supporting Documents And Data Elements

  • Must‑have documents:

  • Commercial invoice, packing list, and any product specification sheets (for scope matching and classification).

  • Exclusion evidence: public notice, exclusion ID, scope language highlighting why your product qualifies.

  • Prior communications: CF28/CF29 correspondence, binding ruling citations, supplier attestations.

  • Calculations: duty overpayment/underpayment, interest where applicable.

  • Data elements to align in ACE:

  • HTS code + any Chapter 99 numbers: country of origin: SPI for FTA: entered value and adjustments: quantities/units: IOR number.

  • Practical example, collectibles:

  • Trading cards often fall under 9504 or 4911 depending on composition/packaging. If tariff changes affect your code, and an exclusion or reclassification reduces duty, correct via PSC: protest if already liquidated.

Note: If you're here more for the hobby than the tariff talk, check our live breaks stream or browse new arrivals in our store, then come back when it's time to model landed costs.

Canada: Post-Release Adjustments And Duty Relief During Tariffs

CARM Client Portal: B2 Adjustments And Re-Assessments

  • Where to submit: CARM Client Portal (CCP). Under CARM Release 2, import accounting is via the Commercial Accounting Declaration (CAD). To correct post‑release, you submit a Request for Adjustment (RFA) to amend the CAD (this effectively replaces the legacy B2 process for commercial importers in most cases).

  • What you can adjust: Classification, value for duty, origin/FTA eligibility, surtaxes, SIMA applicability determinations (with care), and special authority codes.

  • Timing: Corrections should be made as soon as errors are identified. CBSA may impose interest for downward or upward adjustments. Keep an eye on statutory time limits, generally four years to adjust most accounting errors, shorter where specific programs apply.

  • Practical:

  • Maintain supplier origin statements for CUSMA and other FTAs: if you later obtain a valid certificate/statement covering your period, file an RFA for a refund.

  • For retroactive surtax relief (e.g., under remission orders), file an RFA with the remission reference and evidence.

Remissions, Drawbacks, And SIMA Duties

  • Remission Orders: If the Governor in Council issues a remission tied to tariffs or supply chain disruptions, you can seek relief/refund when criteria are met. Reference the specific Order and meet documentation standards.

  • Drawback: If goods are exported or used in the production of exports, claim drawback of duties under CBSA's drawback program (forms and evidence per guidance). Good for accessories or display materials you re-export after shows.

  • SIMA (anti-dumping/countervailing): Adjustments here are sensitive. Overpayment refunds often require a re‑determination or appeal: remission isn't generally available for SIMA. Track normal value updates and importer obligations closely.

For our world, sealed product runs and display fixtures, CARM has made it easier to see your full account position. But you still need disciplined SKU-level evidence if you want your refunds to land without back-and-forth.

European Union: Customs Corrections And Duty Suspensions

Amendment Of Declarations In National Customs Systems

  • Where to submit: Your member state's national system (e.g., Germany's ATLAS, France's DELTA G, Italy's AIDA). You or your customs representative can request a post-clearance amendment or invalidation.

  • When to use: To fix classification, customs value, origin statements, preference claims under EU FTAs (e.g., EU–Canada CETA), or to add/remove additional codes.

  • Timing: Under the Union Customs Code (UCC), you can request an amendment post‑release, but material corrections frequently proceed via a repayment/remission claim.

Duty Suspension, TRQs, And Repayment/Remission Requests

  • Duty suspensions: EU autonomous tariff suspensions can reduce duty rates for specific products not produced in the EU. These are policy-level measures, apply when in force: you can't usually claim retroactively unless explicitly provided.

  • TRQs: Tariff rate quotas grant reduced duty rates until the quota is filled. Ensure your declaration uses the correct additional code while quota is open. If you missed it but were eligible at the time, discuss repayment with customs, member-state practice varies.

  • Repayment/Remission (UCC Articles 116–120):

  • Where to submit: National customs authority using their repayment/remission procedure.

  • Basis: Overcharged duties (e.g., misclassification, valid proof of origin obtained later, clerical error) or equity grounds.

  • Deadline: Typically up to three years from the notification of the customs debt: shorter if national law sets tighter windows.

  • Documentation: Supplier declarations of origin (long-term supplier declarations), statements on origin, classification rationale, invoices, and evidence of quota allocation if applicable.

United Kingdom: CDS Corrections And Repayments

Amending Entries In CDS

  • Where to submit: Customs Declaration Service (CDS) via your software or the trader portal.

  • When to use: Post-clearance amendments to fix commodity code, origin, value, or special procedure indicators.

  • Mechanics: Submit a Post Clearance Amendment (PCA). Some changes require invalidation and re-lodgement. Keep your deferment account and guarantee settings aligned if duty changes.

Tariff Waivers, TRQs, And Remission Applications

  • Repayment/Remission: Use a C285 claim (now supported in CDS) for overpaid import duty, VAT, or excise.

  • TRQs: Apply the correct measure code when quotas are open. If you were eligible but didn't claim at the time, provide evidence and request repayment.

  • Tariff suspensions/waivers: The UK runs its own suspension scheme: use the reduced rate while measures are in force. For past entries, repayment depends on the measure's terms.

  • Timelines: Generally three years to claim repayment of import duty: shorter for VAT adjustments depending on HMRC rules.

Collectors importing boxes for trade shows, store events, or grading roadshows should keep HMRC-friendly evidence packs, commercial invoices, transport docs, and any preference proofs (EU/UK TCA statements of origin). It's not glamorous, but it saves you pennies per box that add up to real money.

Asia-Pacific Snapshots: Where To File In Key Hubs

China: Modification Applications And Duty Refunds

  • Where to submit: China International Trade Single Window or local customs portals.

  • What to file: Post-clearance modification/rectification for misclassification, value adjustments, or origin: refund applications for overpaid duties/taxes.

  • Timing: Deadlines can be tight, often within one year of duty payment for refunds. Local practice varies: consult your broker and the supervising customs house.

  • Documentation: Chinese-language specs, invoices, contracts, and, if claiming preference, certificates/Declarations of Origin.

Japan: Post-Import Corrections And Refunds

  • Where to submit: NACCS via your customs broker or directly if authorized.

  • What to file: Post-importation correction with claim for refund when duties were overpaid (e.g., later-acquired FTA proof, corrected HS code or value).

  • Timing: Statutory periods typically allow up to five years for correction/refund in some cases, but confirm with your district customs office, specific bases have shorter limits.

  • Notes: Japan Customs expects consistency between commercial terms and customs value: be ready with transfer pricing and royalty analysis if relevant.

Singapore: TradeNet Amendments And Duty Remissions

  • Where to submit: TradeNet: refunds through Singapore Customs with supporting forms and evidence.

  • What to file: Permit amendments for post-clearance changes: claims for refund for overpaid duties/ GST. Duty remission programs (e.g., for exhibitions) require pre‑approval.

  • Timing: Commonly within one year from payment for refunds: check the latest circulars.

  • Tip: Keep serial-level records when you import high-value collectibles for shows, proof of re-export underpins later refunds.

Choosing The Right Path: Decision Tree For “PSA” During Tariff Changes

Is The Entry Pre- Or Post-Liquidation?

  • United States: If pre‑liquidation, file a PSC. If post‑liquidation, file a protest within 180 days. If liquidation is soon, evaluate whether to request suspension or push a rapid PSC with your broker.

  • Canada: Use a CARM RFA to adjust your CAD as soon as errors are found. Appeals are for decisions you contest (re‑determinations). Time bars apply.

  • EU/UK/Asia: Pre‑finalization amendments in national systems: otherwise, repayment/remission/refund applications.

Do You Have An Exclusion, FTA Eligibility, Or Valuation Change?

  • Exclusions (U.S. 301/232):

  • Before liquidation: PSC with the correct 99 number or removal of the 99 line as needed.

  • After liquidation: Protest with exclusion evidence and product scope mapping.

  • FTA/Preference Certificates:

  • Later-obtained proof (CUSMA, EU FTAs, UK TCA, RCEP, etc.) can allow refunds within defined windows. File the appropriate adjustment/repayment.

  • Valuation Changes:

  • Transfer pricing true-ups or post‑import rebates require careful treatment. In the U.S., explain 19 CFR 152 adjustments and whether they're dutiable. Provide calculations and intercompany agreements.

Which Portal, Form, And Deadline Apply?

  • U.S.: ACE PSC (pre‑liquidation): ACE Protest Module (within 180 days post‑liquidation).

  • Canada: CARM RFA for CAD adjustments: drawback/remission via CBSA programs within statutory periods (often up to four years).

  • EU: National system amendment or UCC repayment/remission (generally within three years).

  • UK: CDS PCA or C285 repayment (generally within three years).

  • China: Single Window modification/refund (often within one year, local rules apply).

  • Japan: NACCS correction/refund (up to several years, basis-dependent).

  • Singapore: TradeNet amendment/refund (commonly within one year).

Quick gut check: If you're changing data that determines duty, and you're still within the "open" window, correct the entry. If it's finalized, you're looking at a formal claim or appeal.

Pro move we use at CardChasers: keep a live tracker of tariff measures (301 reinstatements, TRQs, suspensions) against affected SKUs. When a measure shifts, we immediately tag eligible entries and file the right correction before the window closes.

Governance, Documentation, And Audit Readiness

Evidence To Keep And How Long

  • Core file: Commercial invoice, packing list, transport docs, purchase orders, and contracts.

  • Technical support: Product specs, composition breakdowns, photos, and samples for classification. For trading cards, keep material composition (paperboard, foil), packaging descriptions, and set lists if relevant to classification.

  • Origin evidence: Supplier statements/certifications, long‑term supplier declarations, REX/R1 numbers where applicable.

  • Program docs: Exclusion IDs (U.S. 301/232), quota allocation proofs, remission orders, drawback filings.

  • Retention: Follow local law, U.S. (5 years), Canada (6 years after end of year), EU/UK (generally 3–10 years depending on member state and tax rules), APAC varies. Keep a single index of everything tied to each entry number.

Broker Instructions And Power Of Attorney

  • Written instructions: Give your broker a change log with what to fix, why it's permitted, and which entries are affected. Include SKUs, HTS, duty impacts, and documentary proof.

  • Power of Attorney (POA): Ensure the POA authorizes PSCs/protests/repayment claims. If you switch brokers mid‑process, confirm who files what to avoid duplicate or missed claims.

  • Controls: Require entry reports monthly: reconcile duties paid to general ledger. Flag anomalies (e.g., sudden HTS shifts or unexpected 99 lines).

Avoiding Common Rejection Reasons

  • Scope mismatch: For exclusions/TRQs, tie your product specs to the exact scope text. Use annotated screenshots of the legal notice if needed.

  • Missing evidence: Don't claim preference without valid origin proof. For late-acquired certificates, cite the legal basis that allows retroactive refunds and include the document.

  • Wrong timing: Filing a PSC after liquidation or a protest after 180 days will sink your claim.

  • Data inconsistencies: HTS changes that don't reconcile with product descriptions or quantities trigger questions. Align everything, including PGA data if relevant.

  • Silence isn't golden: If customs sends a request for information, respond on time and completely. Partial answers extend the pain.

At CardChasers, we treat this like grading: flawless centering, clear corners, and no surface scratches, only here it's your documentation that needs to gem mint.

Conclusion

Tariff volatility rewards the importers who move fast and file correctly. Decoding "PSA" is step one: in the U.S., that usually means a PSC before liquidation or a protest after. In Canada, it's a CARM RFA: in the EU and UK, post‑clearance amendments or repayment/remission: across APAC, national portals handle corrections and refunds under strict timelines.

If you're importing collectibles, from sealed wax to display cases, the difference between catching an exclusion window and missing it can be thousands of dollars a pallet. Build your playbook now: know your portal, your deadline, and your evidence checklist.

And when you need a break from spreadsheets, we're still collectors at heart. Join our daily live card breaks, browse what's new, or tap into our grading services to keep your hits protected. If it exists, we can find it, and if there's a refund on the table, we're going to chase that too.

Frequently Asked Questions

Where to submit PSA during tariffs in the United States?

In U.S. customs, “PSA” usually means a Post Summary Correction (PSC) before liquidation or a protest after liquidation. Submit PSCs in the ACE Secure Data Portal (or via your broker’s ABI). Submit protests in the ACE Protest Module within 180 days of liquidation to challenge decisions and claim refunds.

What is the difference between PSC and protest when teams say “submit a PSA”?

A PSC corrects an entry summary before liquidation—classification, value, origin, or 301/232 exclusions—via ACE. A protest challenges CBP’s decision after liquidation and seeks refunds, filed in the ACE Protest Module within 180 days. Ask: Has the entry liquidated, and do we have documents proving the change?

Where to submit PSA during tariffs in Canada, EU, and the UK?

Canada: file a Request for Adjustment (RFA) to the Commercial Accounting Declaration in the CARM Client Portal. EU: request post‑clearance amendments or repayment/remission via your member state system. UK: submit a Post Clearance Amendment in CDS and use a C285 claim for repayment/remission of overpaid duties.

What documents and data do I need to support a tariff-related PSA submission?

Keep invoices, packing lists, product specs, origin proofs, exclusion evidence (e.g., Section 301 IDs), prior CBP correspondence, and duty calculations. Align ACE/CDS data: HTS and any Chapter 99 codes, origin, FTA indicator, values, quantities, and importer number. Maintain an audit trail explaining the reason and timing of changes.

Does filing a PSC delay liquidation, and what if an exclusion becomes retroactive?

Filing a PSC doesn’t automatically delay liquidation, though CBP may extend or suspend it. If a Section 301 exclusion becomes retroactive, claim it via PSC while the entry is open. If the entry has already liquidated, file a timely protest with the exclusion evidence to pursue a refund.

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