U.S. Customs and Border Protection (CBP) provided an update on March 12 to the Court of International Trade (CIT) regarding its progress in developing the Automated Commercial Environment (ACE) system functionality needed to process IEEPA tariff refunds.

In a filing submitted to CIT Judge Robert Eaton, CBP outlined the development of a new system called the Consolidated Administration and Processing of Entries (CAPE). The update was provided through a declaration from Brandon Lord, Executive Director of Trade Programs for CBP’s Office of Trade.

The CAPE system is being built to streamline refund requests for importers that paid tariffs later invalidated under the International Emergency Economic Powers Act (IEEPA).

CAPE Portal Will Handle IEEPA Refund Requests

At the center of the new system will be the CAPE Claim Portal, a web-based interface that will allow importers and customs brokers to submit refund requests directly through ACE.

Once implemented:

  • A new CAPE tab will appear in ACE accounts

  • Importers and brokers will submit a CAPE Declaration listing entries eligible for refunds

  • ACE will automatically validate entries and calculate refunds

This portal will serve as the main entry point for initiating the IEEPA tariff refund process.

Four Components of the CAPE System

CBP explained that CAPE will consist of four integrated components, each handling a different stage of the refund process.

1. Claim Portal

The Claim Portal allows importers and brokers to submit refund declarations.

As of March 11, CBP reported that development of this component is approximately 70% complete.

The agency has completed the user interface and is currently developing automated validation functions that will verify entries and flag potential errors.

2. Mass Processing System

The Mass Processing component will automatically update entry summaries by removing the IEEPA tariff classifications.

Once removed, ACE will automatically recalculate duties owed.

CBP estimates that development of the Mass Processing component is 40% complete.

Current work focuses on the automated entry summary update process and related system validations.

3. Review and Liquidation / Reliquidation

This component will initiate the review and liquidation process for entries included in an accepted CAPE Declaration.

Key features include:

  • Automatic scheduling of liquidation or reliquidation dates

  • A window for manual CBP review when needed

  • Automated liquidation processing Monday through Thursday each week

CBP estimates that this component is approximately 80% complete.

4. Refund Processing

Once entries are liquidated or reliquidated, the refund process will be handled within the ACE Collections refund module.

Refund amounts will be consolidated and processed through a CAPE-specific workflow.

As of March 11, CBP estimates the Refund component is approximately 60% complete.

CBP is currently performing performance testing on the refund consolidation functionality.

Initial CAPE Rollout Will Cover Most Entries

CBP indicated that the first phase of CAPE will process the majority of formal and informal entries that paid IEEPA duties.

However, some entry types will initially be excluded, including:

  • Entries subject to antidumping or countervailing duties

  • Entries with liquidation status marked Suspended, Extended, or Under Review

  • Certain warehouse withdrawals

  • Entries tied to drawback claims

  • Other specialized entry types

CBP noted that additional functionality will be added in later phases of system development.

Additional Guidance Expected

CBP stated that detailed guidance will be issued to importers and brokers as CAPE development progresses.

Future guidance will outline:

  • CAPE submission procedures

  • Eligibility rules for refund claims

  • Scope of entries covered in each development phase

The CAPE system is expected to play a key role in managing the large-scale refund process resulting from the invalidation of IEEPA tariffs.