The Launch of CAPE Phase 1: Essential Guidance for IEEPA Duty Refunds

Today, April 20, 2026, marks a significant milestone for importers seeking to recover duties paid under the International Emergency Economic Powers Act (IEEPA). 

U.S. Customs and Border Protection (CBP) has officially launched the Consolidated Administration and Processing of Entries (CAPE) Phase 1 functionality within CBP’s digital system for processing imports and exports—the Automated Commercial Environment (ACE).

Following the invalidation of certain IEEPA-based tariffs, CAPE serves as the primary administrative mechanism for securing refunds. However, CAPE is not a “blanket” refund process. CBP has implemented strict technical filters and eligibility windows. The priority now for importers is to ensure that CAPE filings are technically perfect to avoid automated rejections.

Here is the essential guidance for navigating the CAPE portal’s launch.

Defining the Scope: Phase 1 Eligibility and Exclusions

Phase 1 of CAPE is designed to handle “lower complexity” entries. Importers should be aware that the system is not yet equipped to process all refund claims. CAPE Phase 1 will process entries that are either unliquidated or were liquidated within 80 days of the CAPE Declaration submission date. CAPE will also process entries with a liquidation status of suspended, extended, or under review. These entries will maintain their liquidation status until resolved, and the refund, if validated, will be issued following liquidation. Importantly, CBP will perform “netting” by offsetting importers’ payments of invalidated IEEPA tariffs against any underpayments of other duty programs. CBP may also divert refunds to cover any existing fixed and undisputed debts to the U.S. government. 

At this stage, CAPE Phase 1 will not be able to process entries with an active protest, entries flagged for reconciliation (including Entry Type 09 – Reconciliation Summary), entries associated with a drawback claim, entries not filed in ACE or without a liquidation status in ACE, entries subject to antidumping/countervailing duties (AD/CVD) for which the Department of Commerce has issued liquidation instructions that are pending liquidation in accordance with 19 U.S.C. § 1504(d), or entries that fall outside the 80-day liquidation window. 

Filing Mechanics: The CAPE Declaration

To initiate the refund process, an importer must submit a CAPE declaration, which is a CSV file uploaded via the ACE Secure Data Portal. Submission of a CAPE declaration can be performed by the importer of record (IOR) or the licensed customs broker who originally filed the entries within ACE. Lawyers and other third parties are currently unable to file declarations directly. 

If you are an importer who utilized multiple customs brokers, please note that each broker must submit their own declaration for the entries they handled (or you can submit them all). Coordination with service providers is essential to ensure that all eligible entries are captured across importers’ supply chain.

Technical Requirements

CBP has established formatting standards for CAPE declarations. Any deviations will result in automated system errors:

• Submissions must be saved as a .CSV file. Proprietary Excel (.XLSX or .XLS) formats are not compatible.
• Cell A1 of the .CSV file must contain the text “Entry Number” exactly as specified.
• Beginning with cell A2, list the 11-character alphanumeric entry numbers. While dashes are optional, we suggest a consistent format across all entries. Do not repeat any entry numbers.
• Each declaration can accommodate up to 9,999 entry numbers.
• Once a declaration has been filed and accepted, it cannot be amended. However, importers and brokers are free to submit additional declarations to include entries that were omitted from or produced errors in a prior declaration.

Validation and Refund Expectations

Once a declaration is uploaded, the ACE system will provide a validation history. If errors are detected, the system will generate a downloadable report identifying the specific entry numbers that produced errors. 

Once ACE accepts a CAPE declaration and completes validation of specific entries, the entries will be scheduled for automatic liquidation/reliquidation. For entries that are not flagged for additional, manual review, CBP has advised that the importer can generally expect a refund within 60 to 90 days. As with all CBP duty refunds, these refunds will include interest at the statutory rate (currently 7% for individuals and 6% for corporations, compounded daily from the date the duties were deposited).

All IEEPA refunds must be issued via Automated Clearing House (ACH). If an importer’s bank information is not updated in the ACE portal, CBP will validate the claim but hold the refund until the account details are provided. Importers should note that the bank account information designated for refunds is separate from any ACH information used to make payments to CBP. Refund recipients must provide refund-specific bank information through the ACH Refund Authorization tab in their importer subaccount in the ACE portal to ensure that ACH enrollment is active and accurate.

ACE users with importer subaccount access can monitor their refund activity using ACE Reports. The REV-603 Trade Refund report covers successful refunds, and the REV-613 ACH Rejected Refunds report highlights any refunds that have been rejected due to the recipient not being enrolled in ACH Refunds.

Strategic Considerations Moving Forward

The launch of CAPE Phase 1 is the first step in what we expect to be a multiphase rollout throughout 2026. For entries that do not qualify for Phase 1, it is vital to monitor protest deadlines (typically 180 days from liquidation) to preserve your legal right to a refund.

We are closely monitoring the system’s performance during this first week of operation. Importers requiring assistance in auditing entry data or navigating the technical nuances of the ACE CAPE functionality should consult international trade counsel.

For additional technical details, please reference the official CBP IEEPA Refund FAQ.