U.S. Customs and Border Protection (CBP) has provided a detailed update on the rollout of CAPE Phase 1, confirming that the system will go live on April 20 at 8:00 a.m. ET to begin processing IEEPA tariff refunds.

The Consolidated Administration and Processing of Entries (CAPE) tool will operate within the ACE Secure Data Portal and is designed to streamline the large-scale refund process following court rulings invalidating tariffs imposed under the International Emergency Economic Powers Act (IEEPA).

Background: Court Orders Driving Refunds

The CAPE rollout follows a series of key court decisions:

  • March 2: CAFC issued its mandate returning the case to the Court of International Trade
  • March 4: CIT ordered CBP to remove IEEPA duties from entries
  • March 6: CIT allowed time for CBP to develop an automated refund system
  • April 7: CIT reaffirmed instructions to process refunds (with timing flexibility)

These rulings required CBP to build a system capable of handling millions of affected entries, leading to the development of CAPE.

CBP will issue further guidance as additional CAPE functionalities are developed. CBP said it will maintain all information on IEEPA Refunds and CAPE at the IEEPA Duty Refunds page on CBP.gov.

What CAPE Phase 1 Allows

Phase 1 introduces a digital filing process that allows importers to submit refund claims efficiently.

Key Capabilities

  • File CAPE Declarations via ACE Portal
  • Upload up to 9,999 entry numbers per submission
  • Receive automated validation and error feedback
  • Process refunds in a consolidated format (not entry-by-entry)

This significantly reduces administrative burden and speeds up the refund process.

How the CAPE Filing Process Works

Step 1: Submit CAPE Declaration

Importers or authorized brokers upload a CSV file with entry numbers only.

Step 2: ACE Validation

The system checks:

  • Entry format and completeness
  • Importer or broker authorization
  • Data integrity

Invalid submissions are rejected with detailed error messages.

Entry-Level Validations (Important)

ACE also performs detailed checks on each entry, including:

  • Entry must include an IEEPA HTSUS number
  • No drawback, reconciliation, or USMCA deferral entries
  • No open or suspended protests
  • Not subject to AD/CVD pending liquidation
  • Must be within 80 days of liquidation

Invalid entries are removed, but valid ones continue processing.

After these file and entry-specific validations are performed and the CAPE Declaration is accepted, in all or part, it is assigned a unique CAPE claim number.

For more information on the CAPE filing process, please see the ACE Portal: CAPE Declarations Quick Reference Guide

Mass Processing and Duty Recalculation

Once accepted:

  • CAPE removes IEEPA tariff lines
  • Duties are recalculated as if tariffs never applied
  • Refund = difference between paid and recalculated duties
  • Interest is automatically applied per regulations

Liquidation and Reliquidation Timeline

  • Unliquidated entries:
    Set to liquidate 45 days after CAPE acceptance
  • Liquidated entries:
    Reliquidated next business day
  • Special cases (warehouse, suspended entries):
    Follow standard CBP timelines

Refund Issuance and Timing

Refunds will be:

  • Consolidated by Importer of Record (IOR) or designated party
  • Issued as one lump sum per liquidation date
  • Subject to offset for unpaid CBP debts

Expected Timeline:

  • 60–90 days after CAPE acceptance (typical cases)

Important Compliance Notes

Protests

  • Importers may withdraw protests and use CAPE for faster refunds
  • Suspended protests must be reactivated before withdrawal

Post Summary Corrections (PSC)

  • Cannot be used to request IEEPA refunds
  • Must be filed before CAPE submission if needed for other issues

ACH Refund Requirement

  • Refunds are issued electronically only
  • Importers must enroll in ACH payments to avoid delays

What Importers Should Do Now

To prepare for CAPE Phase 1:

  • Confirm ACE Portal access
  • Upload banking information for ACH refunds
  • Identify eligible entries
  • Prepare CAPE CSV files
  • Review validation rules to avoid rejections

Key Takeaways

  • CAPE Phase 1 launches April 20
  • Enables bulk filing of IEEPA tariff refund claims
  • Introduces automated validation and processing
  • Refunds expected within 60–90 days
  • Additional phases will expand coverage