IEEPA Tariff Refunds: The CAPE System Is Now Live

This article is an update to IEEPA Tariff Refunds: What Importers Need to Know, which covers the Supreme Court ruling in Learning Resources, Inc. v. Trump (No. 24-1287), eligibility, and background on the refund process. This update focuses exclusively on the new CAPE filing system and what importers need to do right now.

The CAPE System Is Now the Only Way to File

U.S. Customs and Border Protection (CBP) launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) tool on April 20, 2026.

Phase 1 Scope: The current phase covers unliquidated entries and entries within 80 days of liquidation. Fully liquidated entries where the 180-day protest period has not expired are covered under a separate court order but will not be processed until a later phase due to current system limitations. CBP will provide guidance on subsequent phases as they are released.

CAPE is now the exclusive mechanism for submitting IEEPA tariff refund claims; traditional post-summary corrections and protest procedures may no longer be used for IEEPA refunds. The system operates within CBP’s existing ACE Secure Data Portal and is designed to process refunds in batches by liquidation date and importer of record, rather than entry-by-entry. Interest is included in the refund calculation.

What You Need to Do Before Filing

Two prerequisites must be in place before a refund claim can be processed. Organizations that haven’t addressed these yet should treat them as urgent:

1. ACE Portal account. Both importers of record and authorized customs brokers must have an active ACE Secure Data Portal account. New accounts require Form 5106. Organizations with existing accounts generally do not need to be resubmitted.

2. ACH banking information. CBP ceased issuing paper refund checks on February 6, 2026. All refunds are now electronic via ACH. Banking details must be entered under the ‘Importer’ sub-account in the ACE Portal — this is a manual setup step that does not happen automatically. Note: ACH enrollment must be completed specifically for a refund-specific bank account.

How to Submit a CAPE Declaration

Once your ACE account and banking information are in order, the filing process works as follows:

1. Compile your IEEPA entry numbers — Pull all entry numbers on which IEEPA duties were paid. These can be queried through your ACE Portal account. Only entry numbers go in the CSV file.

2. Upload via the CAPE tab in ACE — Navigate to the CAPE tab within your ACE Portal account and upload a comma-separated values (CSV) file, referred to as a “CAPE Declaration”, listing your entry numbers. CBP will validate each entry and either accept or reject it based on established criteria.

3. Monitor for acceptance — Once a CAPE Declaration is accepted, CBP will remove the IEEPA HTS codes and recalculate duties. Unliquidated entries will be scheduled for liquidation approximately 45 days from the acceptance date. Refunds are then consolidated and disbursed electronically. Refunds also include interest calculated on the IEEPA duties previously paid.

Refund Timing

CBP has indicated that refunds will generally be issued within 60 to 90 days following acceptance of a CAPE Declaration, absent compliance concerns. The clock starts at acceptance, not submission. Organizations that have not yet set up their ACE account or gathered their entry data should move quickly — every week of delay pushes the refund window back accordingly.

Checklist: What to Do Now

• Confirm your ACE Portal account is active and accessible
• Add ACH banking information, specifically for a refund bank account, to the Importer sub-account in ACE
• Pull entry data through ACE to identify all IEEPA-coded entries, and do not rely solely on your broker’s records
• Prepare your CSV file of entry numbers for the CAPE Declaration
• Assess downstream financial impacts, as refunds — including interest — may affect tax positions, transfer pricing, and financial reporting
• Flag entries that fall outside the Phase 1 scope and prepare to act when later phases open