As discussed in our prior article, Supreme Court Ruling on IEEPA Tariffs Opens Door to Billions in Importer Refunds, recent court decisions invalidated tariffs imposed under the International Emergency Economic Powers Act (IEEPA), clearing the way for refund claims by affected importers. At the time, U.S. Customs and Border Protection (CBP) was developing an automated mechanism to handle the unprecedented volume of refunds.
CBP has now launched that system.
As of April 20, 2026, CBP’s Consolidated Administration and Processing of Entries (CAPE) functionality is operational within the Automated Commercial Environment (ACE) and is the exclusive mechanism for requesting refunds of IEEPA duties in Phase 1.
Download GBQ’s IEEPA Tariff Refund Cheat Sheet
Key Guidance From CBP On Using CAPE
Based on CBP’s official IEEPA Duty Refunds guidance, importers should be aware of the following:
- Who may file:
Refund requests may be submitted only by the Importer of Record (IOR) or the authorized customs broker that filed the original entries on the importer’s behalf.
- System access required:
Filers must have an active ACE Secure Data Portal account and must be enrolled in ACH refunds with current bank account information (separate from payment accounts).
- How to file:
Refund requests are made by uploading a CAPE Declaration in CSV format through the CAPE tab in the ACE Portal. Filers do not use ABI to submit these claims.
- Information required:
The CAPE Declaration contains only a list of entry numbers for which IEEPA duty refunds are sought. No additional documentation is required at submission.
- Volume limits:
Each CAPE Declaration may include up to 9,999 entries, and multiple declarations may be filed if needed.
- Phase 1 scope:
Phase 1 is limited to unliquidated entries and certain entries liquidated within 80 days of the CAPE filing date. More complex entry types will be addressed in later phases.
- Refund processing:
Approved refunds will be consolidated and issued electronically via ACH, including applicable interest, rather than processed entry by entry, and are anticipated to be issued 60–90 days following acceptance of the CAPE declaration, unless a compliance concern requires further CBP review.
What Importers Should Do Now
Importers that paid IEEPA tariffs should confirm ACE Portal access, verify ACH refund enrollment, and begin coordinating with internal teams and customs brokers to prepare CAPE Declaration filings. Given the Phase 1 limitations and the volume of claims expected, early preparation and submission may help avoid delays.
GBQ will continue to monitor CBP updates and future phases of CAPE deployment. Please reach out if your company needs assistance working through your data, evaluating eligibility, and preparing refund submissions.
