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IEEPA Refund Update: CAPE Phase One

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

5 May 2026

Latest Developments

According to a recent court filing, U.S. Customs and Border Protection (CBP) expects to start issuing refunds for invalidated IEEPA tariffs as soon as May 11th. Since the launch of the CAPE portal on April 20th, the agency has accepted roughly 21% of all entries, with about 3% of those entries being liquidated and moved onto the refund process.

 

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.

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