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Processing IEEPA Refunds: CBP CAPE System
“CAPE” and IEEPA Refunds: What You Need to Know
CBP to Introduce the CAPE System for IEEPA Refunds Requests
Following our previous communication regarding the IEEPA tariffs, the U.S. Customs & Border Protection (CBP) has announced the first phase of the Consolidated Administration and Processing of Entries (CAPE) system.
CAPE is being implemented to allow for submission of IEEPA duty refund requests and will go live in the Automated Commercial Environment (ACE) on April 20, 2026.
What Importers Should Know
- Importers and brokers will access the CAPE system through their existing ACE Portal accounts.
- Phase 1 of CAPE will permit refund requests for:
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- Certain unliquidated entries
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- Liquidated entries within 80 days of liquidation date
- Entries not eligible for Phase 1 refund requests:
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- Drawback entries
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- Entries flagged for reconciliation
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- ADD/CVD entries
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- Entries covered by an open protest
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- Entries where liquidation is final
- CBP guidance states that only the Importer of Record (IOR) or the broker who filed the entry may submit CAPE declarations to request refunds.
- Once submitted, CAPE declarations will be validated prior to acceptance. Any declaration containing invalid entries will result in those entries being rejected.
- Approved refunds will be processed by CBP and issued electronically via ACH.
- After validation and acceptance, CAPE declarations will undergo a mass processing and CBP review before refunds are issued.
- Refunds will be consolidated by liquidation date and the 4811 party, or by the Importer of Record (IOR) if there no 4811 party is listed.
- CBP indicates that, for Phase 1, refunds are generally expected to be issued within 60 to 90 days following acceptance of the CAPE Declaration.
Please note: Refund processing times may be impacted by legal, administrative or technical delays. Additionally, warehouse entries and entry summaries with extended, suspended, or “under review” liquidation statuses may require additional time for refund processing.
How Importers Can Prepare for CAPE Phase 1
Importers are encouraged to:
- Monitor entries liquidation status to confirm eligibility
- Ensure they have an active ACE importer account to access CAPE and monitor filings and refunds
- Set up ACH refunds through their ACE importer account, if not already established
- Consider filing protective protests for entries nearing or beyond 80 days post-liquidation to preserve refund rights under standard CBP procedures
Additional Guidance
For additional information and CBP guidance regarding CAPE, please refer to the sources linked below.
Delmar Services & Support
Delmar's US Customs Advisory and Consulting experts remain available to assist with any questions regarding the topic at hand.
Delmar will continue to provide pertinent updates as they become available.
For additional information and assistance, please contact your local Delmar Representative.