Customs and Border Protection (CBP) has officially announced the rollout of the long-awaited process to refund duties collected under the International Emergency Economic Powers Act (IEEPA). Beginning April 20, 2026, importers and brokers can begin submitting refund requests through a new Automated Commercial Environment (ACE) portal functionality called Consolidated Administration and Processing of Entries (CAPE).
This is the first actionable step toward recovering IEEPA duties, but the process is structured, phased and requires preparation to avoid delays.
What Is CAPE and How Do Refunds Work?
CAPE is a new tool within the ACE portal that allows importers or their brokers to submit refund requests electronically via a CAPE declaration, which is a comma-separated values (CSV) upload of entry numbers.
Once submitted and accepted, CBP will:
- Remove the IEEPA Harmonized Tariff Schedule (HTS) Chapter 99 duties from the entry
- Recalculate duties owed
- Liquidate or reliquidate the entry
- Issue a consolidated refund by importer and liquidation date
Refunds will be issued electronically via automated clearing house (ACH) only, not by check.
Who Can File and How
Only the following parties can request refunds:
- The importer of record (IOR)
- The customs broker who filed the entry
Key filing mechanics:
- Refunds are requested via a CAPE declaration.
- Multiple declarations may be filed as needed.
Important limitation:
- CAPE cannot be filed via automated broker interface (ABI) and must be done directly in ACE.
Which Entries Are Eligible in Phase 1?
CBP is rolling this out in phases. For now, phase 1 includes eligible and not yet eligible entries.
Eligible entries include:
- Unliquidated entries
- Entries liquidated within the last 80 days from CAPE declaration submission only
- Entries that are suspended, extended or under review (refund issued at liquidation)
Entires that are not yet eligible (future phases) include:
- Entries with final liquidation (meaning those that have passed CBP’s voluntary 90 day reliquidation period after the initial liquidation date)
- Entries on drawback claims
- Entries under open protest
- Entries subject to antidumping and countervailing duties (AD/CVD) liquidation instructions
- Reconciliation entries
Timeline for Refunds
Once a CAPE declaration is accepted:
- Expected refund timing of 60 to 90 days
- Delays may occur if CBP identifies compliance concerns
For entries not yet eligible, refunds will depend on future CAPE phases.
Critical Requirement: ACH Enrollment
CBP has made this clear: no ACH enrollment = no refund issued
Importers must:
- Have an ACE portal account
- Add ACH refund banking information on the ACH refund authorization tab
- Ensure the correct party is designated (IOR or 4811 notify party for foreign importers of record who do not have a U.S. bank account)
If ACH is not set up, refunds will be held until completed
Validation and Filing Risks
CAPE filings are validated at both the file and entry level. Common issues that will cause rejections include:
- Incorrect file format (must be CSV)
- Entry numbers that do not exist or do not match the customs broker filer or importer of record numbers
- Duplicate entries
- Entries without IEEPA HTS lines
Rejected entries are removed, and valid entries continue processing.
Also note:
- CAPE declarations cannot be amended once accepted.
- Additional entries must be submitted on a new declaration.
What You Should Do Now
To position for the fastest possible recovery:
- Confirm ACE portal access: Ensure your ACE importer account is active.
- Enroll in ACH refunds immediately: Verify banking information on the ACH refund authorization tab is complete and accurate.
- Compile your IEEPA entry list: Identify all entries with IEEPA duties paid.
- Coordinate filing strategy: Decide whether filings will be done by your team or your customs broker. Ensure your broker knows your strategy; email them with your decision as soon as possible to prevent accidental duplicate filings.
- Prepare for phase limitations: Separate entry numbers into those eligible now for IEEPA recovery (phase 1) and those not yet eligible for IEEPA recovery (future phases).
Bottom Line
CAPE is the first formal mechanism to recover IEEPA duties, and timing will matter. Importers who are prepared on ACE access, ACH setup and entry data will be in the best position to receive refunds quickly once filing opens on April 20.
