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IEEPA Refund Through CAPE Updates

We will continue to monitor new developments and share any critical information as it becomes available.

5 May 2026

Latest Developments

CBP officially launched Phase 1 of the Consolidated Administration and Processing of Entries (CAPE) process, allowing importers and customs brokers to begin submitting IEEPA duty refund requests through the ACE Portal.

Phase 1 currently applies to:

  • unliquidated entries
  • entries within the voluntary reliquidation period
  • certain warehouse, suspended, and extended entries

CBP has confirmed that refunds will not be issued automatically. Importers or brokers must submit CAPE Declarations through ACE in order to receive refunds.

 

The Consolidated Administration & Processing of Entries (CAPE) system went live on Monday, April 20th, and is only accessible via the ACE Portal. 

CAPE is still quite limited in scope, but it does allow importers to reclaim IEEPA duties and interest.

Importers should continue to monitor entry liquidation statuses, as the liquidation date is the deciding factor for use of the CAPE system. 

How it Works

  1. Importers of Record (IOR) or authorized Customs brokers will file the “CAPE Declaration” by uploading an Excel list of entries to the ACE Portal.
  2. Once accepted, CBP will automatically remove the IEEPA HTS numbers and recalculate duties, generating a revised entry summary in ACE.
  3. CBP will validate and review the updated entry summary and liquidate or reliquidate entries where applicable.
  4. Refunds will be consolidated by IOR number or by the party designated via the CBP Form 4811, based on liquidation dates.

 

Importers can monitor refund status through their ACE portal using the ACE Reports function.

  • REV-603 Trade Refund report covers successful refunds
  • REV-613 ACH Rejected Refunds report covers any refunds rejected due to the recipient not being enrolled in ACH refunds

Phase 1 Details

Included in Phase 1

  • Unliquidated entries
  • Entries that are up to 80 days past liquidation
  • Entries with a liquidation status of suspended, extended, or under review
  • Warehouse and warehouse withdrawal entries (refunds will be issued in the normal liquidation cycle)

Excluded (for now)

  • Entries for which liquidation is final
  • Entries more than 80 days past liquidation
  • Entries covered by an open protest
  • Entries flagged for reconciliation
  • Reconciliation and drawback entries
  • Certain AD/CVD entries pending liquidation instructions
  • Entries not filed in ACE or entries without a valid liquidation status

Key Considerations for Importers

CAPE does not eliminate the need for action today.

Several areas remain unclear, particularly how CAPE submissions may interact with protests or other legal actions.

  • Protest strategy should be evaluated based on timing and risk, as importers have 180 days from liquidation to file and waiting for CAPE may create deadline risk
  • Importers should ensure access to complete entry data across all brokers, either through coordination or through the ACE portal
  • CBP may review CAPE submissions and apply offsets for discrepancies or outstanding obligations, reinforcing the need for accurate classification, proper valuation, clear country of origin support, and complete documentation

How to Stay Prepared

Looking Ahead

  • CBP has indicated that future CAPE phases may expand to include finally liquidated entries
  • Future phases are expected to introduce enhanced validation and enforcement capabilities
  • Eligibility may broaden to include additional entry types, including non-ABI filings

Next Steps

  • Review entry data to identify liquidation timelines and potential protest deadlines
  • Ensure access to the ACE portal and importer account
  • Confirm ACH refund banking information is set up in ACE
  • Coordinate with your account representative or access ACE reporting to obtain complete entry data

If you’re unsure who to contact or would like to discuss how these developments may impact your business, please email dlmarketing@oiaglobal.com, and we’ll route your inquiry to the appropriate contact.

FAQ's

I already receive refunds from CBP via ACH. Do I need to take any action?

No. However, CBP recommends reviewing your current ACH refund authorization information through the ACE Portal to ensure that the information is accurate. For help getting an ACE Portal account, review the ACH Refund Enrollment Overview.

How do I use the ACE Portal to confirm that I have succesfully authorized ACH refunds?

To confirm ACH refund enrollment and see related bank information:

  • Log in to your ACE Portal account
  • Navigate to the Importer sub-account view
  • Select to the “ACH Refund Authorization” tab
  • Click the red “Get Info/Refresh” button

Can I use the new automated ACE Portal application tool to create a new ACE Portal account with the importer sub account view?

Importers and customs brokers can use the new automated application if:

  • An individual or company has an existing 5106 record on file with CBP, and
  • The individual or company does not have an existing ACE Portal top account, and
  • The email address being used is not tied to an account with existing ACE Portal access

I attempted to create an ACE Portal account using the new automated tool for creating an importer sub account but I never receivd the verification code in my email. What should I do?

The verification code is sent to the email address that CBP has in our records for your company. Specifically, it is sent to the email address associated with your company’s physical address in the Importer (5106) record (as opposed to the mailing address). Coordinate with the individual who owns that email address. If you need to update your email address with CBP, contact your customs broker. After your email address has been added, please allow 24 hours for CBP systems to synchronize

I attempted to create an ACE Portal account using the new automated tool for creating an import sub account and I received the following error message: The EIN provided is in use and associated with an existing top account. What should I do?

  1. There is an existing ACE Portal account tied to the Employer Identification Number (EIN) or Importer of Record number provided. You do not need to submit this application. The existing account may be in use by others within your company who do business with CBP. Your company’s ACE Portal Trade Account Owner is responsible for managing access to your company’s ACE Portal account.
  2. If an IR or EIN number (with or without any applicable suffixes) is already associated with an existing ACE Portal account, the automated account creation tool cannot be used to add the Importer sub-account view. The Importer sub-account view can be added by following the steps on CBP’s Managing an ACE Secure Data Portal Account webpage.

I attmpted to create an ACE Portal account using the new automated tool for creating an importer sub account and I received the following error message: No Email On File. What should I do?

CBP does not have an email address on file associated with the Importer of Record number provided. To create your ACE Portal account, CBP needs to send a verification code to the email address we have in our records for your company. Contact your customs broker to have an email address for your company added to your Importer (5106) record. The email address should be associated with your company’s physical address in the Importer (5106) record, as opposed to its mailing address. After your email address has been added, please allow 24 hours for CBP systems to synchronize.

I attempted to enter my bank info and authorize ACH refunds in the ACE Portal and received an error. What should I do?

  • Possible error reason: CBP will reject bank information if the bank routing number does not process FedACH payments. CBP advises that importers and other parties verify that applicable bank routing numbers process FedACH payments.
  • Possible error reason: As part of the ACH refund authorization process, CBP requires that foreign addresses (stored in the Importer sub-account view) are properly formatted, according to the foreign country’s address standards. CBP advises that importers and other parties review and verify that applicable address information is provided in the proper format.

I previously entered my bank information in the ACH Refund Authorization tab, but when i return to the tab my bank information is not there. Why can't I see it?

Use the red “Get Info/Refresh” button on the ACH Refund Authorization tab to see your ACH refund information. Each time you navigate to the tab, the bank information will be blank until the button is pushed.

Once enrolled, where can I monitor the status of refunds for my company?

To monitor the status of refunds to your company, see the Trade REV-603 report in ACE Reports (accessible in the ACE Portal). For help running the report, review the ACE Refund Report training guide.

Do I need an ACE Portal account to receive refunds elecronically via ACH

  • If an importer is not currently set up to receive refunds via ACH, access to an ACE Portal account (with the Importer sub-account view) is required to authorize ACH refunds. For help accessing the ACE Portal to enroll to receive refunds via ACH, review the ACH Refund Enrollment Overview.
  • If an importer is already set up to receive refunds via ACH, ACE Portal access is not required. However, CBP strongly encourages importers to get ACE Portal access to review ACH authorization information.

Do I need to authorize ACH refunds via the ACE Portal if I have a current CBP Form 4811 on file identifying a broker authorized to receive refunds(or I have used the ACE Portal to identify a broker authorized to receive refunds)?

No, if the broker is identified as the refund recipient on all your entries. However, CBP strongly encourages importers to verify that their “4811 notify party” is set up to receive refunds via ACH.

I have a CBP Form 5106 on file with CBP, but I do not have an ACE Portal account. How do I get one?

I have multiple IOR numbers that vary by suffix code. Do I need to establish an importer sub account view for each unique IOR number/suffix code combination and authorize ACH refunds for each one? If so, how do I do that?

Yes, an Importer sub-account is needed for each unique IOR number, even if the same bank account will be used. To access the Importer sub-account for each unique IOR number, follow these steps:

  • Submit a request letter to CBP via email, on company letterhead, signed by the TAO or a legally authorized company official
  • IMPORTANT: When submitting a request to add one or more sub-accounts to an existing top account, ensure that company information (e.g., company name, company address) in the request is provided exactly as it was on the originally submitted ACE Portal application form.
  • Provide the necessary information related to the requested sub-account(s), including a list of all the IOR numbers for which access is needed. The full list of IOR numbers may also be provided in the body of the email message.
  • Submit the application form via email to ACE.Applications@cbp.dhs.gov.

How do I create a notify party in the ACE Portal?

For help creating a notify party, review the ACE Portal: Create a Notify Party training guide.

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