CBP Launching CAPE for IEEPA Refunds: What Importers Need to Know

CBP Launching CAPE for IEEPA Refunds: What Importers Need to Know

Apr 14, 2026

U.S. Customs and Border Protection (CBP) is introducing a new system that will significantly impact how importers recover duties imposed under the International Emergency Economic Powers Act (IEEPA).


The system, called CAPE (Consolidated Administration and Processing of Entries), is scheduled to go live on April 20, 2026. It is designed to streamline what has traditionally been a slow, manual refund process.


Why This Matters

Recent rulings from the Court of International Trade (CIT) have directed CBP to remove IEEPA duties from certain entries and issue refunds where applicable. Given the scale of impacted entries—estimated in the billions of dollars—CBP developed CAPE to handle this volume efficiently.


At the same time, CBP has confirmed the system is in its final stages of testing ahead of deployment, signaling that importers should begin preparing now.


What CAPE Does

CAPE introduces an electronic process within the ACE Portal that allows importers and customs brokers to:


  • Submit refund claims digitally
  • Process large volumes of entries in a single submission
  • Automatically remove IEEPA duties from entries
  • Receive consolidated refunds, including applicable interest


Rather than processing refunds one entry at a time, CAPE consolidates them, significantly improving efficiency.


How the Process Works

The CAPE process follows a structured workflow:


  1. A CAPE Declaration is submitted through the ACE Portal
  2. The system validates the entries for eligibility
  3. IEEPA tariff lines are removed and duties are recalculated
  4. CBP liquidates or reliquidates the entries
  5. Refunds are issued, typically in a consolidated payment


For most eligible entries, CBP expects refunds to be issued within approximately 60 to 90 days from submission .


Key Limitations to Understand

CAPE Phase 1 is not available for all entries. It is limited to:


  • Certain unliquidated entries
  • Entries within approximately 80 days of liquidation


Additionally, some entries are not eligible, including those:


  • Subject to antidumping or countervailing duties (AD/CVD)
  • Associated with drawback claims
  • With open or suspended protests
  • Falling outside specific validation parameters


Understanding eligibility is critical, as incorrect submissions will be rejected.


Important Compliance Considerations

While CAPE simplifies the refund process, it does not replace existing legal requirements.


Importers are still responsible for:


  • Monitoring liquidation timelines
  • Filing protests when necessary
  • Preserving their legal rights for ineligible entries


In other words, CAPE is a tool—not a substitute for a compliance strategy.


Additional Operational Details

CBP estimates that approximately 82% of eligible entries can be processed electronically through CAPE, representing a substantial portion of total IEEPA duty exposure.


  • Refunds will be issued via ACH (electronic payment) only
  • Payments will be consolidated rather than issued per entry
  • CBP may offset outstanding debts before issuing refunds
  • Entries may be grouped into a single refund payment


Strategic Considerations for Importers

Importers should carefully evaluate how CAPE fits into their overall refund strategy:


  • Entries within the eligibility window may benefit from faster CAPE processing
  • In some cases, previously filed protests may be withdrawn and resubmitted through CAPE
  • Post Summary Corrections (PSCs) cannot be used to request IEEPA refunds


Each situation should be reviewed individually to determine the best approach.


What You Should Do Now

To prepare for CAPE:


  • Confirm your ACE Portal account is active
  • Ensure ACH refund enrollment is completed
  • Identify potentially eligible entries
  • Coordinate with your customs broker


Early preparation will help avoid delays once the system goes live.


Final Thoughts

CAPE represents a meaningful improvement in how CBP processes IEEPA duty refunds. However, it also introduces new requirements around eligibility, timing, and submission accuracy.


For importers with significant exposure to IEEPA duties, this system offers a faster and more efficient path to recovery—provided it is used correctly.


How ARI Can Help

ARI Shipping Corp. is actively assisting clients with:


  • Identifying eligible entries
  • Preparing CAPE submissions
  • Advising on protest versus CAPE strategies
  • Managing the administrative process

If you believe your shipments may qualify for refunds, now is the time to evaluate your options and act accordingly.