U.S. Customs and Border Protection (“CBP”) is preparing to launch a new automated process for refunding tariffs collected under the International Emergency Economic Powers Act (“IEEPA”).
Beginning April 20, 2026, importers and their brokers will be able to submit refund requests through the Consolidated Administration and Processing of Entries (“CAPE”) functionality within the Automated Commercial Environment (“ACE”).
This new functionality provides a streamlined, electronic pathway to pursue IEEPA tariff refunds at scale.
How the CAPE Refund Process Will Work
Under Phase 1 of CAPE, refund requests will be submitted by uploading a CAPE Declaration (a CSV file listing eligible entry numbers) through the ACE Portal.
Once submitted:
- CBP will validate the declaration and individual entries for eligibility
- For accepted entries, ACE will remove IEEPA tariff lines (HTS Chapter 99) and recalculate duties
- Entries will then be liquidated or reliquidated, as appropriate
- Refunds will be consolidated and issued electronically after CBP review
Each CAPE submission can include up to 9,999 entries, and multiple submissions may be filed.
Eligible Entries (Phase 1)
Phase 1 is limited in scope. CAPE will accept:
- Unliquidated entries, and
- Entries liquidated within the past 80 days
Certain entries are excluded from Phase 1, including:
- Reconciliation entries or entries flagged for reconciliation
- Drawback claims
- Entries subject to open protests
- Entries subject to AD/CVD
- Entries not filed in ACE
- Entries liquidated more than 80 days ago
Additional functionality may be introduced in future phases.
Key Filing Mechanics
To submit a CAPE Declaration:
- Download the CAPE template from the ACE Portal
- Populate the file with eligible entry numbers
- Save the file as a CSV and upload via the CAPE tab
- Monitor validation results and claim status in ACE
CBP will validate both the file format and each entry number and will provide feedback for any rejected entries.
Timing of Refunds
For eligible and accepted claims, CBP has indicated that refunds will generally be issued within approximately 60–90 days after acceptance of a CAPE Declaration, subject to review and liquidation timing.
Critical Requirement: ACE & ACH Setup
Importers must ensure they are properly configured in advance:
- ACE Portal access is required to submit CAPE claims
- ACH refund enrollment is mandatory
CBP will issue refunds only via ACH, and refunds will not be released until valid banking information is on file in ACE.
Importers without ACH refund setup should prioritize enrollment immediately to avoid delays.
Important Considerations
While CAPE provides a new administrative pathway for refunds, it does not replace or extend legal remedies. Importers should continue to:
- Evaluate whether to file protests on liquidated entries to preserve refund rights
- Consider broader litigation strategies and deadlines
Given Phase 1 limitations, many entries may not be eligible for immediate refund through CAPE.
How TLR Can Assist
TLR is prepared to support clients through all aspects of the IEEPA refund process, including:
- Running ACE reports
- Identifying eligible entries
- Preparing CAPE Declaration files
- Submitting CAPE claims through ACE
- Monitoring claim status and resolving validation issues
- Filing protests, where appropriate, to preserve and protect refund rights
As the customs broker of record, TLR can submit CAPE Declarations on behalf of our clients for entries we filed. If you have questions about CAPE eligibility, filing strategy, or refund recovery, please contact compliance@shiptlr.com.
This alert is for informational purposes only and does not constitute legal advice.
