CBP Confirms April 20 CAPE Launch for IEEPA Refunds: What Importers Should Do Now

U.S. Customs and Border Protection (“CBP”) has now issued operational guidance for Phase 1 of CAPE, the new ACE-based process for obtaining refunds of duties paid under the International Emergency Economic Powers Act (“IEEPA”). Phase 1 is scheduled to go live at 8:00 a.m. EDT on April 20, 2026. The most important takeaway for importers is that refunds will not be automatic. Companies can now work with their customs brokers, logistics teams, and finance personnel to identify the right entries, confirm ACE and ACH readiness, and prepare for filing once the portal opens.

For more information, CBP will be maintaining all information on IEEPA Refunds and CAPE at the IEEPA Duty Refunds page on CBP.gov.

Key Takeaways

• CAPE Phase 1 is scheduled to launch on April 20, 2026, at 8:00 a.m. EDT.
• Refunds will not be automatic. The importer of record or the filing broker must submit a CAPE declaration through ACE.
• The filing itself is simple in form but important in execution. The submission is a CSV file listing entry numbers only, with up to 9,999 entries per declaration.
• Phase 1 is aimed at entries most likely to move quickly, including most unliquidated entries and entries within 80 days after liquidation.
• Certain entry types will not be accepted in Phase 1, including entries involving reconciliation, drawback, open or suspended protests, certain AD/CVD matters, entries over 80 days past liquidation, and entries for which liquidation is final.
• CBP says valid refunds for eligible unliquidated entries generally should issue within 60 to 90 days after CAPE acceptance, absent a compliance concern requiring further review.
• Refunds will be issued electronically through ACH, so ACE access and refund banking instructions should be confirmed now.

What CAPE Phase 1 Will Cover

• Most entries that are unliquidated or up to 80 days past the liquidation date
• Entries with liquidation status of suspended, extended, or under review, although those entries will keep that status and refund will issue only after liquidation
• Warehouse and warehouse withdrawal entries, although CBP will process those in the ordinary course when they are ready for liquidation

What CAPE Phase 1 Will Not Process

• Entries flagged for Reconciliation
• Entry type 09 Reconciliation entry
• Entry summary associated with a Drawback entry
• Entry type 08 USMCA Duty Deferral entry
• Entry summary with an Open or Suspended Protest
• Entry summary with “open” or “closed” liquidation status (i.e., Temporary Importation under Bond entry)
• AD/CVD entry summary in pending liquidation status
• Entry summary over 80 days past the liquidation date
• Entries not filed in ACE and entries without a liquidation status in ACE
• Entries for which liquidation is final

How the Filing Process Works

In practical terms, CAPE is designed to be easy to file but unforgiving if the wrong entries are submitted. The importer or its filing broker will submit a comma-separated values (“CSV”) file, listing entry numbers only, and ACE will then run both file-level and entry-level validations before accepting the claim in whole or in part.

• Importers of Record (“IORs”) and brokers will have the ability to access the CAPE Tab through their ACE Portal account.  To file a CAPE Declaration, the IOR or broker will upload a CSV file listing up to 9,999 entry numbers on which IEEPA duties have been paid and for which they are requesting an IEEPA duty refund.  Only the entry numbers should be included in the CSV file – no other entry-related information is needed.
• A separate CAPE Declaration may be submitted for additional entry numbers beyond the first 9,999.
• The CAPE tab will be available in the Importer, Organizational Broker, and Filer sub-accounts in ACE.
• A downloadable CAPE Declaration template file will be available through the “Upload” button in the CAPE tab.
• The CAPE Declaration may only be submitted by the IOR associated with the entry summaries or by the broker that filed the entry summaries.

CAPE Declarations will go through two sets of validations before being accepted: file declaration validations and entry specific validations.

CAPE File Declaration Validations

The submission will undergo file validations to confirm before it is accepted and into the ACE Portal and assigned a CAPE claim number. The file validations will make sure that the Declaration contains complete entry numbers that are properly formatted, that the submitter is the IOR for the listed entries or the authorized broker that filed the entry summaries on behalf of the IOR, and the CSV file is not corrupted.

• The results from this series of validations will be shown in the File Upload Status column of the File Uploads section of the CAPE tab. Filers can view the detailed results by selecting the File Upload Job # and downloading the Validation Result File, enabling filers to correct the identified issues and resubmit the request on a new CAPE Declaration.
• If the submission fails any part of the file validation series, ACE will reject the CAPE Declaration. The system will identify, and filers will be able to see the specific errors that triggered the rejection on the CAPE Tab, allowing filers to identify and correct any errors and resubmit a new CAPE Declaration.

Entry Specific Validations

Once the submission passes the file validations, CAPE will run entry-specific validations. If an entry summary fails any of the entry-specific validations listed below, ACE will remove that individual entry summary from the CAPE Declaration but will continue processing the remaining entry summaries listed.

• After the system completes the entry-specific validations, ACE will display the results and identify any rejected entries and the reason for their rejection.
• Filers can review the results of the entry-specific validations by navigating to the CAPE Claim Status section, selecting the Claim Number and downloading the resulting file. If the filer corrects the entry-specific errors identified by ACE, it may resubmit the entry summary on a separate CAPE Declaration.

The following entry types will not be accepted for validation:

• Entry summary flagged for Reconciliation
• Entry type 09 Reconciliation entry
• Entry summary associated with a Drawback entry
• Entry type 08 USMCA Duty Deferral entry
• Entry summary with an Open or Suspended Protest
• Entry summary with “open” or “closed” liquidation status (i.e., Temporary Importation under Bond entry)
• AD/CVD entry summary in pending liquidation status
• Entry summary over 80 days past the liquidation date
• Entries not filed in ACE and entries without a liquidation status in ACE
• Entries for which liquidation is final
•  Protests:
  • If a protest has been submitted solely for IEEPA refund purposes and the entry summary is within 80 days of the liquidation date, an importer may withdraw the protest and add the entry summary to a CAPE Declaration for faster refund processing. 
  • Should the protest be in suspended status, you may reach out to your processing Center to request the suspension be removed. Once removed, the importer can withdraw their protest, then the entry summary can be submitted on a CAPE Declaration.

• Post Summary Corrections (“PSC’s”):
  • Filers are prohibited from initiating an IEEPA duty refund request by filing a PSC.
  • PSCs that are filed due to requesting a refund for entries eligible for duty free treatment due to the lapse of the African Growth and Opportunity Act and the Haiti Hope Help Agreement during October 1, 2025 through February 3, 2026, or any other issue, should be filed prior to submitting a CAPE declaration.

• Drawback:
  • IORs and brokers should ensure they submit a CAPE Declaration for the processing of entries for which IEEPA refunds are due prior to filing a drawback claim.
• Surety Payments
  • IORs and brokers should ensure they do not submit a CAPE Declaration for entries on which a surety paid IEEPA duties in whole or in part.

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

Mass Processing

• Mass processing will be performed on all entry summaries that were accepted on the CAPE Declaration.
• The duties owed on the entry summary will be recalculated as if IEEPA duties were never owed.  The projected refund will be the difference between the duties, taxes, and fees paid on the entry summary and the recalculated duties, taxes, and fees owed on the entry summary. Interest is calculated on these refunds, as it is on any interest eligible refund issued by CBP, in accordance with 19 CFR 24.36.

Review and Liquidation/Reliquidation

• Once the mass processing is complete, unliquidated entry summaries will be set to liquidate 45 days from the CAPE Declaration acceptance date, except for entries in suspended, extended, or “under review” liquidation status.
• Warehouse and warehouse withdrawal entry summaries will not be set to liquidate 45 days from the CAPE Declaration acceptance date.
  • Instead, the liquidation process for warehouse entries will continue to be performed by CBP in the normal course after all withdrawals have been made and the warehouse entry is ready for liquidation, at which time CBP will process the refund of the IEEPA duties.
• Liquidated entry summaries will reliquidate the next business day.

Refund Timing

• The individual entry summary refunds will be consolidated by IOR or designated 4811 party and liquidation date before they are dispersed in one lump sum.
• For any unpaid debts owed to CBP, a check for any unpaid debts to CBP must be made before the issuance of the refund, and the refund amount will equal the difference between the IEEPA duties to be refunded and the unpaid bill(s).
• For unliquidated entries other than warehouse entries and entries with extended, suspended, or “under review” liquidation status, importers and authorized brokers may anticipate that valid IEEPA refunds will generally be issued within 60 – 90 days following acceptance of a CAPE Declaration, unless a compliance concern requires further CBP review.

ACH Payments

• All refunds from CBP will be issued electronically through ACH payments in accordance with Executive Order 14247.
• If recipients do not already have refund bank account information on file, they must provide it through the ACE Portal by accessing the ACH Refund Authorization tab in an Importer sub-account.
• To ensure there is no delay in receiving the refund, the IOR or designated “notify” 4811 party, must be signed up for ACH refunds. Review ACH Refund sign up guidance here: ACH Refund Enrollment.
• For instructions on obtaining an ACE Portal account, adding an Importer sub-account, or submitting bank information for refunds, recipients should review the ACH Refund Enrollment Overview page
• If the 4811 designation specifies that the “notify” party should receive refunds on the IOR’s behalf, and the “notify” party is listed on an entry, any refund for that entry will be issued to the “notify” party instead of directly to the IOR.

Monitoring Refund Status

• ACE Portal users with Importer sub-account access can monitor refund activity using ACE Reports. The new REV-615 CAPE Refunds Trade Report will provide CAPE-related refund information.

What Importers Should Do Now

• Pull the right ACE data now. In many cases, the broker can use an ES-003 or similar ACE report and filter for the relevant IEEPA Chapter 99 tariff lines to generate the list of entry numbers that will need to be submitted through CAPE.
• CBP has stated that legal counsel should not file CAPE Refund Declarations for clients. However, Clark Hill can help clients and brokers organize the correct universe of entries before submission. Our trade team can also prepare the required CSV file for you or for your broker to use in the CAPE Declaration.
• Identify all entries on which IEEPA duties were paid.
• Separate those entries into practical buckets: unliquidated, within 80 days after liquidation, protested, and clearly ineligible for Phase 1.
• Confirm that the importer or any designated 4811 “notify” party is enrolled for ACH refunds through ACE.
• Confirm who will submit the CAPE declaration: the importer of record or the broker that filed the entry summaries.
• Resolve or at least flag entries involving protests, drawback, reconciliation, AD/CVD, warehouse issues, or surety payments before filing.
• Decide whether any protest filed solely for IEEPA refund purposes should be withdrawn so the entry can move through CAPE more quickly.

Training

• CBP will publish a Quick Reference Guide (QRG) for CAPE users on the ACE Training and Reference Guides webpage. https://www.cbp.gov/trade/automated/training-and-reference-guides (CAPE guide does not appear to be up yet).

Contact Clark Hill

If you have questions regarding the content of this alert, please contact any member of Clark Hill’s International Trade Practice:

• Mark Ludwikowski (mludwikowski@clarkhill.com; 202.640.6680)
• Kevin Williams (kwilliams@clarkhill.com; 312.985.5907)
• Kelsey Christensen (kchristensen@clarkhill.com; 202.230.9889)
• Ashley Gifford (agifford@clarkhill.com; 202.640.6655)
• Laura M. Quesada (Lquesada@clarkhill.com; 202.40.0170)
• Amal Sheheen (asheheen@clarkhill.com; 202.552.2354)
• Onjoly Purification (Opurification@clarkhill.com; 202.552.361)

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