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IEEPA Refund Update: CAPE Phase One
The IEEPA Refund Process is still being developed. Our team will provide updates as more information becomes available.
2 April 2026
CBP provided a status update on March 31st in the Atmus Filtration case, offering the clearest view to date on how the CAPE system is expected to function as part of the IEEPA duty refund process.
While Consolidated Administration & Processing of Entries (CAPE) represents progress, Phase 1 is limited in scope, and CBP has not clarified how it will interact with existing strategies such as filing protests.
What CAPE Phase 1 Covers
CAPE Phase 1 is expected to apply to:
- Unliquidated entries and entries within the 90-day voluntary reliquidation window
- Entries in Suspended, Extended, or Under Review status
- Warehouse and warehouse withdrawal entries (Refunds issued through the normal liquidation process, not immediately)
- Recently liquidated entries within ~80 days (to allow reliquidation by day 90)
Refunds for eligible entries are expected to be issued through the normal liquidation process rather than immediately. Liquidation is the point when CBP finalizes an entry, which typically occurs around 314 days after the entry date, followed by a 180-day window to take action. CBP has indicated that review and liquidation may take up to 45 days after submission, assuming no additional compliance issues.
What Is Not Included in Phase 1
At this stage, CAPE Phase 1 is not expected to include:
- Entries beyond the 90-day reliquidation window (finally liquidated)
- Entries with open protests
- Reconciliation entries and drawback entries
- Entries not filed in ACE or lacking a valid liquidation status
- AD/CVD entries where liquidation instructions have already been issued and are pending
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.
