Summary: U.S. Customs and Border Protection launched its IEEPA tariff refund program, CAPE, on April 20, 2026. This new system helps importers to recover duties paid under the International Emergency Economic Powers Act — but strict eligibility rules, filing sequences, and tight timelines mean importers must plan ahead before submitting a claim.
CAPE: CBP’s Answer to the Tariff Refund Challenge
A long-awaited opportunity to recover duties paid under the International Emergency Economic Powers Act (IEEPA) is now within reach.
On March 6, 2026, the U.S. Court of International Trade (CIT) paused its order directing the U.S. Customs and Border Protection (CBP) to immediately begin issuing refunds on tariffs collected under IEEPA after recognizing they needed time to build an infrastructure to manage the sheer volume and value of refunds.
The result: the Consolidated Administration and Processing of Entries (CAPE), a new automated functionality within the CBP’s Automated Commercial Environment (ACE) designed to handle IEEPA refunds at scale.
Phase 1 of the IEEPA tariff refund process launches on April 20, 2026. It’s important for businesses impacted by IEEPA tariffs to understand how this program works, what it covers, and where its limitations lie because it could mean the difference between recovering significant sums or leaving money on the table.
How Does the CAPE Program Work?
Given the unprecedented refund challenge, rather than processing tariff reimbursements entry-by-entry, CAPE consolidates refunds and interest payments across multiple entries and issues a single lump-sum payment to Importers of Record (IORs).
CAPE Declaration Submission Process
The submission process is designed to be straightforward. An IOR or authorized broker submits a CAPE Declaration through the CAPE tab in the ACE Portal. You can list up to 9,999 entry numbers with IEEPA duties paid, using a comma-separated values (CSV) file.
Validation and Refund Calculation
Once the declaration is validated and accepted, CBP removes the applicable IEEPA Harmonized Tariff Schedule (HTS) Chapter 99 numbers from the entry summaries. Duties are then recalculated as if the IEEPA charges were never assessed, and a refund is prepared for the difference. Interest is automatically included and calculated under 19 CFR 24.36.
Electronic Payment and Additional Declarations
All payments are made electronically through ACH, in compliance with the March 2025 executive order. If more than 9,999 entries are involved, additional declarations can be filed separately.
What to Expect: The 7-Step CAPE Claim Lifecycle
Understanding the lifecycle of a CAPE claim will help importers plan accordingly and avoid costly mistakes. Here is what happens from submission to refund:
Step 1 — File the CAPE Declaration:
The IOR or authorized broker who originally filed the entry summaries uploads a CSV file listing entry numbers only through the CAPE tab in ACE. No additional entry data is required.
Step 2 — File validation:
ACE performs an initial review to confirm that entry numbers are properly formatted, the submitter is the IOR or authorized broker, and the CSV file is not corrupted. If a submission fails at this stage, it is rejected in full and must be corrected and resubmitted.
Step 3 — Entry-specific validation:
ACE reviews each individual entry. Any entry that fails a specific validation check is removed from the declaration, but the remaining entries continue processing. Submitters can see exactly which entries were rejected and why and can resubmit those entries on a separate CAPE Declaration after correcting errors.
Step 4 — CAPE claim number assigned:
Once validations are complete and the declaration is accepted in whole or in part, it receives a unique CAPE claim number for tracking purposes.
Step 5 — Mass processing:
CBP removes all applicable IEEPA HTS Chapter 99 numbers at the entry summary line level, creating a new minor version of the entry summary, and recalculates what duties would have been owed without IEEPA charges.
Step 6 — Liquidation or reliquidation:
Unliquidated entry summaries are set to liquidate 45 days from the CAPE Declaration acceptance date, with exceptions for entries in extended, suspended, or “under review” status. Already-liquidated entries reliquidate the next business day following processing.
Step 7 — Refund issuance:
Refunds are consolidated by IOR and liquidation date, then disbursed electronically via ACH. For most entries, importers can expect refunds within 60 to 90 days of CAPE Declaration acceptance, accounting for the 45-day CBP review period plus Treasury processing time, unless a compliance concern requires additional review.
What Are the Limitations on IEEPA Tariff Refunds Under Phase 1?
Phase 1 of CAPE is designed to address specific unliquidated entries and those entries within 80 days of liquidation. This means not every affected entry qualifies for processing now, and importers with more complex situations will need to wait for subsequent phases. Beyond the scope limitation, there are six categories of entries that are explicitly excluded from the CAPE Declaration process:
- Reconciliation and drawback entries, including entry types 09 and 47, as well as any summaries associated to a drawback entry, are excluded from Phase 1.
- Entries with unresolved or suspended protests must have the protest resolved before CAPE submission. Withdrawals for IEEPA refunds are allowed within 80 days of liquidation. If a protest is in suspended status, the importer can request removal of that suspension from their processing center, then withdraw and resubmit via CAPE.
- Antidumping and countervailing duty (AD/CVD) entries in pending liquidation or have issued instructions are not eligible for CAPE processing.
- Entries more than 80 days past the liquidation date are not eligible under Phase 1.
- USMCA Duty Deferral (entry type 80) and Temporary Importation under Bond entries with either an “open” or “closed” liquidation status are excluded.
- Warehouse and warehouse withdrawal entries are processed normally once all withdrawals have been made and are not on the standard 45-day liquidation timeline.
Importers should avoid submitting CAPE Declarations for entries where a guarantor, rather than the importer, paid the IEEPA duties, whether fully or partially. Entries with an extended, suspended, or “under review” liquidation status, will maintain their current status, and any refunds will be processed when liquidation happens, not within the standard 45-day timeline.
Key Compliance Considerations Every Importer Must Know
Beyond understanding what the program covers and excludes, importers must pay close attention to several practical and compliance-related factors that should be built into their approach before filing a CAPE.
Sequence matters
Make sure you submit CAPE Declarations for IEEPA-affected entries before any drawback claims are filed against those same entries. Filing in the wrong order can complicate or delay refunds or cause an entry to become ineligible for CAPE processing altogether.
ACH enrollment is not optional
All CBP refunds are now issued electronically per federal requirements. If the IOR or designated 4811 party is not enrolled for ACH refund payments, the refund will be delayed. Check your ACH enrollment status right away through CBP’s ACH Refund Enrollment guidance.
Post Summary Corrections (PSCs) are not a path to IEEPA refunds
CBP explicitly prohibits using PSCs to initiate an IEEPA duty refund request. For other issues, like duty-free eligibility for goods imported during the lapse of the African Growth and Opportunity Act (AGOA) or the Haiti HOPE/HELP Agreement, PSCs should be filed before submitting a CAPE Declaration.
Monitor claims actively through ACE Reports
ACE portal users with importer sub-account access can track refund activity using the new REV-615 CAPE Refunds Trade Report. Given the volume of entries that may be submitted, maintaining visibility into claim status is essential throughout the process.
The 60–90-day estimate is a guide, not a guarantee
CBP’s stated timeline assumes no compliance concerns arise. If an entry is flagged for further review, the timeline extends. Importers should not assume payment will arrive within a fixed window without actively tracking claim status.
Direct channels exist for questions
CBP has established dedicated email addresses for CAPE inquiries. Technical questions should go to [email protected], and general inquiries can be directed to [email protected].
Final Thoughts: Act Now to Recover What Your Business Is Owed
Phase 1 of CAPE is intentionally limited in scope. Importers with entries not eligible under Phase 1 shouldn’t assume their refunds are lost; more complicated cases, such as certain AD/CVD cases, reconciliation entries, and drawback-adjacent scenarios, are expected to be considered by the CBP in future phases. It’s important to stay informed as the program evolves, regularly check CBP’s Cargo Systems Messaging Service (CSMS) updates and the IEEPA Duty Refunds page on CBP.gov.
Importers who stay informed as the program evolves, act decisively, and seek the right guidance will be best positioned to recover what they are owed under the court-ordered IEEPA refund program.
