CBP Launches CAPE for IEEPA Tariff Refunds

Today, U.S. Customs and Border Protection (CBP) launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE), the first version of its automated IEEPA duty refund system. The system is now live within the Automated Commercial Environment (ACE), allowing importers of record (IORs) and their authorized brokers to submit refund claims for IEEPA duties through a new, structured digital process.

With today’s rollout of CAPE, importers should be aware of important limitations, eligibility requirements, and open questions as they begin filing.

How CAPE Works: A Step-by-Step Overview

As of today, a new CAPE tab is available in your ACE Portal account. From there, the process consists of five stages:

1. Submission

The IOR or the original broker of record files a CAPE Declaration by uploading a CSV file containing entry numbers. Each declaration can include up to 9,999 entries, and filers may submit multiple declarations. CBP will validate the identity of the submitting party.

2. Validation

Each declaration goes through two rounds of validation:

• File validation confirms that the CSV is properly formatted and not corrupted.
• Entry validation confirms that the entry numbers are valid, and that IEEPA duties were actually paid on those entries.

For any rejected entries, CBP will provide a hyperlinked report identifying the reason for each rejection. Rejected entries are excluded from the original claim, but can be corrected and resubmitted as part of a new declaration.

3. Claim Assignment

After passing both validations, each declaration receives a claim number.

4. Review and Liquidation

CBP reviews the entries, validates the refund amounts, and liquidates or reliquidates each entry.

5. Refund

Refunds are issued via ACH direct deposit to the IOR or the designated notify party. Refund status can be tracked in ACE through reports REV-603 and REV-613.

Which Entries Are Eligible for Phase 1?

CAPE Phase 1 covers entries that are either still unliquidated or that liquidated within the preceding 80 days. CBP estimates that Phase 1 will address approximately 63% of eligible entries.

Expected refund timelines vary depending on entry status:

• Unliquidated entries or those liquidated within the past 80 days: Expect refunds approximately 60–90 days after CAPE acceptance.
• Entries with suspended, extended, or under-review status, along with warehouse entries: Refunds will be issued later, once the entry liquidates.

Entries Excluded from Phase 1

The following entry types are not eligible for refunds via CAPE Phase 1:

• Entries flagged for reconciliation, including Entry Type 09 (Reconciliation Summary)
• Entries designated on a drawback claim
• Entries covered by an open protest
• Entries not filed in ACE, or entries without a liquidation status in ACE
• Entries subject to antidumping and countervailing duties (AD/CVD) for which the Department of Commerce has issued liquidation instructions, but are pending liquidation
• Entries where liquidation is already final (i.e., more than 80 days past liquidation)

CBP intends to expand CAPE in future phases to cover finally liquidated entries and other excluded entry types, though timing and details on the process for those phases remain undefined.

Refunds and Payments

Refunds will be paid via ACH direct deposit to the IOR or a designated notify party. Importers can file a Post Summary Correction (PSC) to update the notify party on an entry if needed.

However, CBP has indicated that importers may not file PSCs to request IEEPA duty refunds. All unliquidated entries must go through CAPE.

Disbursement timing: Operationally, refunds will flow through ACE, which is already under significant strain. An estimated 53 million entries across more than 330,000 importers are being introduced into a new process, and potential system bottlenecks could lead to delays.

Validation protocols also remain unclear, particularly around how submitted entries will be reviewed, how discrepancies will be handled, and how rejections will be managed. This will likely place added pressure on importers and brokers to reconcile and correct data, further impacting timelines.

AD/CVD Entries

CBP is still determining how to handle pre-liquidation refunds for suspended entries subject to AD/CVD orders, which encompasses approximately 166,000 entries. Unlike standard entries, where the refund process is largely automated at liquidation, pre-liquidation refunds for AD/CVD entries require manual processing that would place significant strain on CBP’s operations. CBP has not provided a timeline for resolving this category.

Other Important Takeaways

• Protests and CAPE: You can withdraw a previously filed protest to include that entry in CAPE Phase 1. However, be mindful of the liquidation timeline on that entry before withdrawing.
• Court of International Trade (CIT) filers: Even if an IOR has filed suit at the CIT, they still need to file through CAPE to request refunds.
• Future phases: Now that Phase 1 is deployed, CBP will begin work on subsequent phases. The next CAPE progress update is expected on April 28, 2026.
• Additional information is available on CBP’s IEEPA Refunds page.

What Importers Should Do Now

With CAPE Phase 1 now live, importers should take the following steps:

1. Confirm ACE Portal access and set up ACH refunds. Confirm that a valid U.S. bank account is on file for electronic payments.
2. Identify which of your entries qualify for Phase 1, versus those that will need to be addressed in later phases.
3. Audit your entry data. CBP plans to review entries and may offset duty refunds with other duties, taxes, or fees that are owed. Flexport’s Audit Your Customs Broker tool can automatically audit your entries for filing errors, identify tariff stacking issues, and estimate duties you may have over- or underpaid.
4. Continue filing protests for entries nearing the protest deadline. Until CBP provides official guidance on how liquidated entries (post-voluntary-liquidation) will be handled, filing protests helps preserve your right to a refund.
5. Sign up with Flexport Trade Advisory. Our team can help you navigate the CAPE process, prioritize your filings, and manage your refund claims. Flexport’s Trade Advisory team has created a dedicated CAPE Task Force to manage the entire CAPE filing process on behalf of customers, and we’ve already begun filing declarations.

What’s Ahead for IEEPA Duty Refunds

CAPE Phase 1 is a major step forward for IEEPA refunds, but many questions remain. While the system is expected to cover roughly 63% of eligible entries, the remaining 37% still lack defined timing and process clarity. Some refunds may be processed relatively quickly, while others could remain unresolved for an extended period.
Importers who act quickly—by setting up their ACE accounts, auditing their entry data, and working with an experienced trade advisory team—will be in the best position to recover their IEEPA duties as efficiently as possible.

Contact Flexport Trade Advisory to get started, and calculate what you’re owed with the Flexport Tariff Refund Calculator.