IEEPA Tariff Refunds: Who Can Claim Through CAPE and When

Trade remedies4 min read

Executive Summary

CAPE lets eligible importers of record and their authorized customs brokers request IEEPA duty refunds through the ACE Portal.

Phase 1 covers certain unliquidated entries and entries liquidated within the preceding 80 days; Phase 2 adds entries flagged for reconciliation when the reconciliation entry is not yet on file.

Phase 3 covers finally liquidated entries filed by plaintiffs for which a court ordered reliquidation; CBP deployed it in October 2026.

CBP generally expects valid refunds within 60 to 90 days after CAPE Declaration acceptance, but missing bank details, compliance review, offsets and entry-level duty calculations can delay or reduce payment.

IEEPA tariff refunds are requested through CAPE, the Consolidated Administration and Processing of Entries functionality in CBP’s Automated Commercial Environment (ACE). The CBP IEEPA Duty Refunds page explains the filing process and current phases for importers of record (IORs) and authorized customs brokers.

Which Entries Do CAPE Phases 1 to 3 Cover?

CAPE currently covers defined entry groups, and Phase 3 is narrower than a general refund path for finally liquidated entries.

  • Phase 1: Certain unliquidated entries and entries liquidated within the preceding 80 days. The 80-day window lets CBP process and reliquidate entries within its 90-day voluntary reliquidation period.
  • Phase 2: Entries flagged for reconciliation when the reconciliation entry, also called Entry Type 09, is not yet on file. The entries must otherwise meet Phase 1 timing limits. After the CAPE Declaration is accepted, the filer may file the reconciliation entry. If that entry is already on file, the underlying entries are not eligible in this phase.
  • Phase 3: Finally liquidated entries filed by plaintiffs for which a court has ordered reliquidation. CBP deployed this phase in October 2026, as described in its court filing about CAPE.

Phase 3 does not open CAPE to every importer with a finally liquidated entry. The court filing says CBP notified eligible plaintiffs who had provided a valid IOR number by July 30, 2026, and would provide further instructions to plaintiffs who supplied the number later.

Who Can File an IEEPA CAPE Declaration?

Only the IOR or the authorized customs broker that filed the entries on the IOR’s behalf may submit the CAPE Declaration. An attorney cannot file one solely as counsel. A broker may combine entries filed for different IORs, up to 9,999 entries in one Declaration.

The filer needs an ACE Secure Data Portal account. The Declaration is a CSV file listing the entry numbers, uploaded through the CAPE tab in the ACE Portal. ABI, the Automated Broker Interface, is not used to submit it. Each entry must be in ACE with accepted status and must meet the phase and validation requirements. CBP validates the file and entries; accepted entries continue processing, while rejected entries are removed and the filer can see the rejection reason.

When Did CBP Add Each CAPE Phase?

The first three CAPE phases were deployed between April and October 2026.

  • April 20, 2026: Phase 1 became available in ACE.
  • June 29, 2026: Phase 2 functionality became available for qualifying entries flagged for reconciliation with no reconciliation entry on file.
  • October 2026: CBP deployed Phase 3 for qualifying plaintiffs’ finally liquidated entries.

These deployment dates describe when functionality became available, not a deadline to file a Declaration.

How Long Do CAPE Refunds Take?

CBP says valid IEEPA refunds generally issue within 60 to 90 days after acceptance of the CAPE Declaration, unless a compliance concern requires more review. For entries that are extended, suspended or under review, and for warehouse entries, validated refunds are issued at liquidation instead. After liquidation or reliquidation, most refunds appear in the designated ACH account within 3 to 5 weeks.

CBP consolidates refunds by IOR or the IOR’s designated Form 4811 notify party, and by liquidation date. The refund reflects the entry’s final duty calculation, not necessarily the IEEPA duty amount originally expected. CBP nets overpayments and underpayments across the entry, so other duties, taxes or fees still owed can reduce the refund or result in a bill. CBP may also apply a refund to an IOR’s legally fixed and undisputed unpaid debts.

What Should Importers Check Before Filing?

Check account access, entry eligibility and refund banking details before uploading because an accepted CAPE Declaration cannot be amended or canceled.

  • Confirm the filer. Use the IOR or the customs broker that filed the entries, with an active ACE Portal account.
  • Validate the entry list. Use the CAPE template and confirm each entry number, phase eligibility and accepted ACE status. An entry can appear on only one accepted Declaration; submit additional eligible entries in a new one.
  • Enroll for ACH refunds. Add current U.S. bank details in the ACE Portal. CBP holds payment until the required information is on file.
  • Track the result. Use ACE reports, including ES-022 for entry and refund details. CBP does not email CAPE status updates.

CBP says it is evaluating later functionality for other entry types, including entries with reconciliation already on file and finally liquidated entries outside the Phase 3 group. It has not provided a deployment date for those categories.

Sources

This publication is for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. Reading it does not create, and receipt of it does not constitute, an attorney-client relationship. Readers should not act on this information without seeking advice from qualified counsel. The views expressed are those of this site and its owner as of the date of publication. Although we try to keep this content complete, accurate and up to date, we assume no responsibility for its completeness, accuracy or timeliness.

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