The information below is from March 13, 2026. For the latest CAPE update, please refer to our recent trade alert released on April 13, 2026, available here.

Importers Responsible for Identifying and Claiming IEEPA Refunds.

On March 12, U.S. Customs & Border Protection (CBP) filed its status report to the Court of International Trade (CIT) regarding refunds of IEEPA tariffs. In this report, CBP announced they are developing a new capability within ACE to facilitate the IEEPA refund process called CAPE (Consolidated Administration and Processing of Entries).

What is CAPE?
CBP is proposing that importers will have to apply for a refund of IEEPA duties through CAPE. This implies CBP will not proactively issue IEEPA refunds.

The CAPE Claim Portal will be web-based and serve as the entry point for importers and brokers to submit IEEPA refund requests (“Cape Declaration”) to CBP.

CBP has not provided a target date for CAPE’s completion and launch. CAPE will contain four components, which are in various stages of completion:

• Claim Portal Component (70% complete according to CBP)
  • New tab in the ACE portal available to brokers and importers
  • Importers and Brokers will be able to submit IEEPA refund request (CAPE Declaration) to CBP as a CSV file containing a list of entry summaries for which they are requesting refunds
    • Filers will NOT use ABI to file in CAPE portal
    • ACE will conduct two validations:
      • File validation – verifies whether refund request contains all required information, whether the information is properly formatted, the submitter is the IOR or authorized broker, and whether CSV file is not corrupted).
        • ACE will reject if the submission fails any part of the file validation.
      • Entry validation (after successful file validation)
        • Confirms that entry number on CSV file exists in ACE.
        • That at least one IEEPA 99 number was declared on the entry.
        • If the entry summary fails the validation, ACE will remove that entry from CAPE declaration BUT will process remaining entries.
        • After validation, ACE will allow the filer to review the results and identify any rejected entries.
        • Filer might be able to correct entry specific errors on a separate CAPE Declaration upload.
• Mass Processing Component (40% complete)
  • Cape Mass Processing will automatically remove any applicable IEEPA HTS numbers from entry summaries submitted and validated by CLAIM.
  • Will run ACE duty calculation validations (normal ACE entry summary process in existence today, which automatically reviews all declared HTS numbers to confirm the correct duties owed are listed on the entry summary).
  • Mass processing will calculate duties as if IEEPA were not declared.
  • After that, the system will accept CAPE Declaration.
• Review and Liquidation/Reliquidation Component (80% complete)
  • This component will initiate the review and liquidation / reliquidation process for entries identified in the accepted CAPE declaration.
  • It will set entries to liquidate / reliquidate on a specific number of days from the acceptance date, allowing CBP to conduct a manual review as needed.
  • The review and Liquidation / Reliquidation component will update the underlying entry summaries to reflect the new total duties paid and will automatically calculate interest.
  • It will process liquidation / reliquidation of entries on a CAPE Declaration Monday through Thursday each week.
• Refund Component (60% complete)
  • ACE will direct entries to a refund process once the entry summaries in the accepted CAPE Declaration reach the schedule liquidation / reliquidation date.
  • The CAPE Refund component will consolidate refunds by liquidation / reliquidation date and IOR or a party IOR has designated to receive refunds on its behalf on a CBP Form 4811 (4811 designee party).
  • Refunds will be sent electronically to the designated bank account.

What will CAPE not cover?

CBP expects a phased development for CAPE. In the first phase, CAPE will have the ability to process a majority of formal and informal entries with IEEPA duties, other than:

• Unliquidated entries subject to AD/CVD.
• Entries for which liquidation status in ACE is “suspended”, “extended”, or “under review”.
• Other types of entries such as warehouse withdrawals and entries designated on a drawback claims.

What should importers do?

• Set up an ACE account immediately if you don’t already have one
  • ACE access is critical to receive these refunds. It is also important for entry audits and for receiving CBP communications.
• Ensure you can receive electronic refunds via ACH
  • This must be set up as soon as possible within the ACE portal.
• Continue to track your IEEPA duties
  • Understand how much you have paid in duties, so you can compare this to the refund once CBP issues one.
• File Protests on entries containing IEEPA duties, which are within 90-180 days after the liquidation. After an entry is liquidated, CBP has the statutory authority to reliquidate the entry only within 90 days of the original liquidation, therefore entries beyond the 90 days are at risk.

Deringer will continue to monitor CIT’s actions and other developments. In view of these events, we urge you to sign up for electronic refunds as soon as possible and consult with a Customs Attorney.

Deringer Customers: Get Started with Electronic Refunds Here

To let us know how we may best assist you, please complete our client form for IEEPA protests and electronic refunds. Go to the Form

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.