TRADE ALERT – IMPORTS
HEADLINE	CAPE IEEPA Refund System Updates
DATE	April 10, 2026
AGENCY	U.S. Customs and Border Protection
EFFECTIVE DATE	April 20, 2026
SUMMARY	U.S. Customs and Border Protection (“CBP”) announced the launch plan for Phase 1 of the Consolidated Administration and Processing of Entries (“CAPE”). CAPE is designed to process International Emergency Economic Powers Act (“IEEPA”) duty refunds.   Phase 1 will only cover entries that are unliquidated or within 80 days past liquidation.   Importers of Record (“IOR”) or a customs broker that filed entries on behalf of the IOR will be able to use CAPE to recover IEEPA duty refunds.   Action Items for Importers with IEEPA Tariff Exposure:   1. Establish importer ACE account and ACH refund payment capabilities with CBP, utilizing the new web-based-based application. 2. Identify all entries that are unliquidated or up to 80 days past their liquidation date. 3. Monitor entries for liquidation and protest deadlines. 4. Consider filing an action at the CIT for entries for which liquidation is final.
BACKGROUND	On February 20, 2026, the President revoked the Executive Orders that directed the imposition of the IEEPA tariffs. On March 4, 2026, the CIT issued an order (amended March 5, 2026) directing CBP to liquidate all unliquidated entries without IEEPA duties. The CIT also ordered that all entries for which liquidation is not final to be reliquidated with a refund of the IEEPA duties.     CBP has previously provided updates to the CIT regarding development of the refund platform CAPE, including on March 31, 2026, where CBP stated that Phase 1 is designed to process entries that are unliquidated or for which the 90-day voluntary reliquidation period under 19 U.S.C. § 1501 has not expired.
DETAILS	On April 10, 2026, CBP announced that it will launch Phase 1 of CAPE on April 20, 2026. CAPE is designed to consolidate refunds of IEEPA duties, including interest, by IOR number. CBP intends to implement CAPE through a phased approach, adding more functionality in future phases. Scope Phase 1 is limited to entries that are unliquidated or up to 80 days past their liquidation date. Phase 1 will also process entries with liquidation status of “suspended,” “extended,” or “under review.”   However, Phase 1 will not cover entries in the following categories: • Entries that have been flagged for reconciliation, as well as Entry Type 09 – Reconciliation Summary; • Entries on a drawback claim; • Entries covered by an open protest; • Entries not filed in ACE and entries without a liquidation status in ACE; • Entries subject to AD/CVD for which liquidation is pending in accordance with 19 U.S.C § 1504(d); and • Entries for which liquidation is final. Based on the information presented, “finality of liquidation” is based on the 90 day voluntary reliquidation period provided to CBP under 19 U.S.C. 1501. CBP is using 80 days, rather than 90 days to allow for processing.   Submission Process To file a request for refunds of IEEPA duties, IORs must upload a CSV file containing a list of entry numbers for which IEEPA refunds are requested (“CAPE Declaration”). A CAPE Declaration is limited to 9,999 entries, but multiple CAPE Declarations may be submitted. CBP has stated they will provide a CAPE Declaration template file. A customs broker that filed the entries on behalf of the IOR may submit a CAPE Declaration.   Based on the information posted by CBP, it appears that it will be up to the importer to assure that none of the entries listed in the CSV file are subject to any of the listed restrictions, and that the claim will be rejected if there are non-qualifying entries.   Filers must submit the CAPE Declaration through a new tab in ACE and cannot use the Automated Broker Interface to file a CAPE Declaration.   Validation Once ACE performs a file validation check and an entry-specific validations check, CBP will remove the IEEPA duties and recalculate the duties due without IEEPA, generating an updated entry. CBP will then review the updated entry and liquidate or reliquidate the entry. CBP will issue consolidated refunds to the IOR or to the “notify” party, if designated on the original entry. Refunds will be paid electronically by the Automated Clearing House that the IOR has provided in the ACE Portal.   CBP has stated that they intend for valid IEEPA refunds to be issued within 60-90 days following system acceptance of the CAPE Declaration, unless further CBP review is required.   CBP has also clarified that the trade community is prohibited from initiating an IEEPA duty refund request by filing a Post Summary Correction.   Additional Considerations Importers are advised to consider taking additional steps to preserve the right to recover duties paid on entries that were liquidated more than 80 days before the filing of their CAPE report. Such action will likely depend on the date that the entry liquidated. Some of those entries would have liquidated before the Supreme Court decision invalidating the IEEPA tariffs.  As stated by the Court of International Trade (“CIT”) in AGS Company Automotive Solutions v. U.S. Customs and Border Protection Slip Op 25-124 (Dec. 15, 2025), the protest of these entries would be futile; the CIT can order the reliquidation of these entries if they have jurisdiction under 28 U.S.C. § 1581(i), suggesting that a filing at the CIT would be required to recover these duties.  Depending on the date of the filing of the CAPE Declaration, other entries may have liquidated after the Supreme Court decision and may require a protest to preserve the rights to recovery. See Atmus Filtration, Inc. v. United States Court No. 26-01259 Order dated March 20, 2026: “importers should be aware of the remedies available under 19 U.S.C. § 1514 (Protest against decisions of Customs Service).”  We anticipate that there will be additional direction from the CIT or CBP on this point.   Action Items for Importers with IEEPA Tariff Exposure:   1. Establish importer ACE account and ACH refund payment capabilities with CBP, utilizing the new web-based-based application. 2. Identify all entries that have IEEPA tariffs and are unliquidated or up to 80 days past their liquidation date. 3. Monitor entries for liquidation and protest deadlines. 4. Consider filing an action at the CIT for entries for which liquidation is final.
BASIS	N/A
CITE	CBP CSMS # 68315804 (April 10, 2026): Introduction – Consolidated Administration and Processing of Entries (CAPE) for IEEPA Refunds, April 20, 2026 Deployment   CBP Trade Information Notice Consolidated Administration and Processing of Entries (CAPE) Phase 1 (April 8, 2026)   CBP IEEPA Duty Refunds

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