---
title: IEEPA Refund Using CAPE
description: Understanding the CAPE system for IEEPA refunds. Be prepared for a review prior to a potential refund.
image: https://www.jetworldwide.com/hubfs/IEEPA-CAPE-REFUND-GRAPHIC-JETSHIP.webp
---

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### Jet Worldwide Blog

Connecting people, parcels, and businesses around the world!

![American flag with headline ](https://www.jetworldwide.com/hubfs/IEEPA-CAPE-REFUND-GRAPHIC-JETSHIP.webp)

# IEEPA Refund Using CAPE

[ Timothy Byrnes ](https://www.jetworldwide.com/blog/author/timothy-byrnes)

CBP launches the CAPE refund system on April 20, 2026 to return an estimated 165 to 175 billion dollars in unlawfully collected IEEPA tariffs to roughly 330,000 importers. CAPE is not a simple refund portal. It is a review engine that recalculates entries, validates data, and flags discrepancies before processing refunds. Importers should audit their entries for HTS classification accuracy, country of origin declarations, and duty calculations before filing.

$165-175B Total Refunds

330,000 Affected Importers

53M+ Entries Filed

April 20 CAPE Launch Date

**Key Takeaway:** The CAPE system launches April 20, 2026. Most importers think they are preparing for a refund. They should be preparing for a review. CAPE is not a payment tool. It is a review engine with a refund function attached.

The result of the Supreme Court's decision*, an estimated $165 to $175 billion in unlawfully collected duties must be returned to roughly 330,000 importers across more than 53 million entries. The Court of International Trade directed CBP to begin processing refunds, and CBP responded by building a purpose-built system called CAPE -- the Consolidated Administration and Processing of Entries -- inside its Automated Commercial Environment (ACE) portal.

Summary: US Customs has defined a way to secure refunds for IEEPA tariffs. The refunds will be paid to the importer of record and managed via the same customs systems through which the duties were processed. [Definitions to know.](https://www.jetworldwide.com/blog/ieepa-refund-cape#definitions)

What is most unclear is how ["Express Carriers" (FedEx, UPS and DHL) will manage IEEPA refunds](https://www.jetworldwide.com/blog/ieepa-refund-cape#courier-ieepa-refunds).  

UPDATE: The First Day of CAPE was largely a success!

![IEEPA-CAPE-ENTRY-MESSAGE](https://www.jetworldwide.com/hs-fs/hubfs/IEEPA-CAPE-ENTRY-MESSAGE.webp?width=623&height=334&name=IEEPA-CAPE-ENTRY-MESSAGE.webp)

## CBP Confirms CAPE Is Working: Inside the April 28 Court Filing

The first sworn accounting of CAPE Phase 1 performance, straight from the U.S. Court of International Trade docket.

On April 28, 2026, U.S. Customs and Border Protection (CBP) filed a declaration with the U.S. Court of International Trade. This provided the first official accounting of how CAPE refund tool has performed since its April 20 launch.

The numbers tell a clear story of a system that is working.

![IEEPA-refund-eligility-phase1-jetship](https://www.jetworldwide.com/hs-fs/hubfs/IEEPA-refund-eligility-phase1-jetship.webp?width=824&height=538&name=IEEPA-refund-eligility-phase1-jetship.webp)

### Phase 1 Launch — The Numbers

On launch day (**April 20, 2026)**  ACE recorded a nearly 70 percent increase in daily log-ins compared with its previous all-time record.

CAPE Phase 1 — First Six Days

CBP figures as of 8:00 p.m. ET, Sunday, April 26, 2026

| CAPE declarations submitted | 75,306 |
| --- | --- |
| Declarations that passed file validations | 47,315 |
| Entries accepted for IEEPA duty removal | 11,222,927 |
| Entries already liquidated and in refund pipeline | ~1,740,000 |
| Entries rejected at entry-specific validation | 2,124,394 |
| Total downtime since launch | 18 minutes |

### What the Numbers Mean

**The volume is enormous.** More than 11.2 million individual entries cleared CAPE's entry-specific validations in the first six days. 

**Refunds are actually moving.** Roughly 1.74 million entries — about 15.5 percent of the accepted pool — have already been liquidated and entered the formal refund pipeline.

**Rejections are real, but recoverable.** Roughly 2.12 million entries failed entry-specific validation — close to one in six. Importers (or their brokers) can resubmit corrected declarations.

### System Reliability

The only interruption since launch was an 18-minute pause on April 20, during which CBP briefly reconfigured resources to optimize processing capacity. The uptime record of +99.9% percent over the first six days is proof that CAPE is running strong.

[Source](https://storage.courtlistener.com/recap/gov.uscourts.cit.17610/gov.uscourts.cit.17610.26.0_2.pdf)

****Supreme Court Background:** The Supreme Court's landmark 6-3 ruling in **Learning Resources v. Trump** on February 20, 2026 determined that the International Emergency Economic Powers Act (IEEPA) was not a valid basis for imposing tariffs. The Court held that the IEEPA's broad "regulate" language does not convey taxing authority via tariffs.*

***What is CAPE:** [Consolidated Administration and Processing of Entries (CAPE)](https://www.cbp.gov/sites/default/files/2026-04/ace_portal_-_cape_declarations_508c.pdf) is the refund process built within the ACE Portal. **CAPE is not a payment tool. It is a review engine with a refund function attached.***

*Phase 1 is limited to certain unliquidated entries and certain entries that are no more than 80 days past liquidation. *

On the surface, the process looks straightforward: upload a CSV of entry numbers, wait 60 to 90 days, receive your refund electronically via ACH. But trade compliance professionals who have studied the mechanics of the system are sounding alarms.

## What Are IEEPA, CAPE, ACE, ACH and Liquidation? The Key Systems Behind US Tariff Refunds

- IEEPA DUTY: International Emergency Economic Powers Act: Import duty collected between March 2025 and February 24, 2026 ruled unlawful.
- CHAPTER 99 TARIFFS: The section of the US Harmonized Tariff Schedule (HTS) used to charge IEEPA tariffs. This section exists specifically for such temporary or special tariff measures.
- ACE -- Automated Commercial Environment: The US customs electronic system used by customs brokersfor processing of import entries.
- CAPE -- Consolidated Administration and Processing of Entries:The refund system in ACE purpose built to manage IEEPA tariffs refunds.
- ACH -- Automated Clearing House: The electronic funds transfer network through which CBP disburses all refunds, including IEEPA duty refunds processed through CAPE. As of February 2026 all CBP refunds are electronic.
- Liquidated Entry: The liquidation process is the period - usually around 10 months - between the entry date and when   CBP finalizes an entry. Importers usually then have a 180-day window to flag any issues or disputes with the finalized tariff bill. Most entries with IEEPA tariffs have either not been liquidated or within 80 days of liquidation. (Under 19 CFR Part 159, liquidation is the final determination of duties based on tariff classification, value, origin and admissibility.)

![IEEPA-QUALIFIED-LIST-JETSHIP](https://www.jetworldwide.com/hs-fs/hubfs/IEEPA-QUALIFIED-LIST-JETSHIP.webp?width=810&height=443&name=IEEPA-QUALIFIED-LIST-JETSHIP.webp)

## CAPE Phase 1 Is Live: What to File and When

Importers of record and licensed customs brokers may now file CAPE Declarations through ACE.

### Steps to Prepare for an IEEPA Refund

1. **Consider, but do not rush into, a CIT filing.** Some importers with large exposure have filed protective actions at the Court of International Trade. The CIT Orders purportedly apply to litigants and non-litigants alike (so even if you do not file, you can benefit from the decision). For most small importers a costly CIT filing is not practical. 
2. **Create an ACE importer account if you do not already have one.** This is the prerequisite for everything that follows.
3. **If you have an ACE account but have not logged in within the past 45 days, contact ACE Support immediately.** Dormant accounts deactivate and must be reactivated before you can file. ACE Support runs 24/7.
4. **Enrol in ACH refunds inside the ACE Portal using a US bank account.** CBP no longer issues paper checks. Refunds flow only via ACH. How refunds for FedEx, UPS and DHL informal entries will be managed is not clear. 
5. **Pull an ACE report of all entries with IEEPA duties paid.** Cross-reference the liquidation dates and flag any entries that error out. These become the raw data for your CAPE Declaration.

### Filing a Phase 1 CAPE Declaration

A Phase 1 CAPE Declaration is a CSV (comma-separated values) file containing **only entry numbers**. Two conditions must be met for each entry included:

- IEEPA duties were paid on the entry.
- The entry is either **unliquidated**, or was liquidated **less than 80 days** before the Declaration submission date.

For importers with recent formal-entry exposure that falls inside the 80-day window, Phase 1 is worth acting on now. The CSV itself is simple, but the preparation — confirming IOR status, cleaning entry data, and resolving ACE errors — takes time.

[![ACH-processing-USCBP](https://www.jetworldwide.com/hs-fs/hubfs/ACH-processing-USCBP.webp?width=796&height=414&name=ACH-processing-USCBP.webp)](https://www.cbp.gov/sites/default/files/2025-05/cbp_form_401.pdf)

## What CAPE Actually Does

CBP has described CAPE as having four integrated components:

1

#### Claim Portal

Importers or their authorized brokers upload a CSV file listing entry numbers (up to 9,999 per declaration). The system validates the file format, confirms the filer's authorization, and checks each entry number against ACE records.

2

#### Mass Processing

For validated entries, the system strips the IEEPA-specific Chapter 99 HTS codes, removes the corresponding duties, and recalculates what is owed without IEEPA. This creates a new version of the entry summary inside ACE.

3

#### Review, Liquidation, and Re-liquidation

CBP reviews the updated entries and initiates liquidation (for unliquidated entries, scheduled 45 days from acceptance) or reliquidation (for recently liquidated entries within the 80-day window).

4

#### Refund Processing

After liquidation, refunds are consolidated by importer of record and liquidation date, then disbursed electronically through ACH.

**The critical distinction is in the third step.** The real process is not "upload then refund." It is "upload, then review, then liquidation or reliquidation, then refund." 

## Understanding Error Messages in CAPE

Importers are started to question error messages in CAPE. The error codes provide information necessary to fix the problem.

The early system-driven ones were driven by high volume. Message "not started" is not a failure but rather informing the user that the batch is in queue. In this case, resubmitting is the wrong move because it creates duplicate filings. 

- Errors like "unable to calculate duty" or entries flagged as under review, suspended, or unfindable mean CBP isn't ready to touch the entry yet and CAPE won't override that.
- The more serious ones are the tariff construction errors — no valid IEEPA Chapter 99 line. This occur occurs when the chapter 99 number isnot aligning with the underlying HTS, or 9903.03 Section 122 codes showing up where they don't belong. This indicates an incorrect entry.
- Errors saying the entry can't be found, doesn't match your account, or fails batch validation usually trace to EIN mismatches, entry number formatting, or the wrong filer submitting. If you're not the recognized party tied to that entry in ACE, you don't get the refund.
- Then there are the hard stops: entries that are finally liquidated, tied to drawback, flagged for reconciliation, or under protest or litigation will be rejected outright. Two specific codes are already repeat offenders — Error 864 effectively locks your submission once accepted (no PSC cleanup afterward, so what you submit is what you're stuck with), and inactive ACE account errors mean you can't play at all until reactivation.

[See US CBP CAPE Messaging Definitions](https://www.cbp.gov/sites/default/files/2026-04/ace_portal_-_cape_declarations_and_error_definitions.pdf)  
![CAPE-error-codes](https://www.jetworldwide.com/hs-fs/hubfs/CAPE-error-codes.webp?width=852&height=479&name=CAPE-error-codes.webp)  
![cape-entry-validation-errors](https://www.jetworldwide.com/hs-fs/hubfs/cape-entry-validation-errors.webp?width=843&height=839&name=cape-entry-validation-errors.webp)

## CAPE Filing Guidelines for IEEPA Tariff Refunds

### Key System Requirements

#### Filing Authorization

Only the Importer of Record (IOR) or the broker who filed the original entry may submit CAPE Declarations. No third parties are authorized to request these refunds.

#### Account Prerequisites

Filers must maintain an active ACE Portal account and complete ACH enrollment with current banking information before any refunds can be processed.

#### File Format

CSV uploads should contain only entry numbers (without dashes) and filer codes.

### Filing Process and Timing

#### System Availability

CAPE filing became available on April 20, 2026, accessible through a  tab in the ACE Portal.

#### No Filing Deadline

Unlike Post Summary Corrections (PSC), CAPE has no submission deadline. PSC cannot be used for IEEPA refunds. New ACE Entry Summary Error Code   
Condition Code: 864: PSC NOT ALLOWED – REFUND REQUESTED  
Explanation: PSC is not allowed due to a CAPE Refund in process

#### Error Handling

Individual entry rejections will generate error codes but will not halt processing of remaining valid entries. Corrections and resubmissions are permitted.

### Refund Processing Details

#### Processing Schedule

Refunds are processed Monday through Thursday with expected completion within 60 to 90 days of CAPE Declaration acceptance, unless compliance reviews are required.

#### Batching Method

Refunds are consolidated by liquidation (or reliquidation) date and grouped by IOR or CBP Form 4811 designee. A PSC can be filed to modify the 4811 party if needed.

#### Interest Calculation

Interest accrues from the liquidation date, not the entry date.

#### Payment Method

All refunds are issued electronically via ACH to the designated bank account registered in the ACE Portal.

### Special Considerations

#### Litigation Cases

Importers with pending Court of International Trade (CIT) cases may still file through CAPE.

#### Compliance Period

The 80-day compliance review period includes calendar days, not business days.

#### Legal Compliance

All refunds will be issued in accordance with applicable laws and any relevant court orders.

## The Review Engine No One Is Talking About

Trade professionals who have been tracking the CAPE development through court filings and CBP declarations from Brandon Lord, Executive Director of Trade Programs at CBP.  The features that reveal CAPE's intent to only refund correctly admited entries.

![IEEPA-cape-entry-jetship-1](https://www.jetworldwide.com/hs-fs/hubfs/IEEPA-cape-entry-jetship-1.webp?width=384&height=309&name=IEEPA-cape-entry-jetship-1.webp)

### Scenario-Based Testing

CBP has been conducting intensive testing across the four CAPE components. Stress-testing how the system handles entries where the data does not align cleanly -- mismatched classifications, inconsistent country of origin declarations, or duty calculations that do not reconcile.

### Manual Processing for AD/CVD Entries

Entries subject to antidumping or countervailing duties are excluded from Phase 1 automation entirely. When they are eventually processed, it is expected to be a much more manual process.  For importers with complex duty structures, this is a probably something to expect.

### Workload and Resource Constraints

CBP has been candid with the Court about the operational challenge. The agency is not going to review every single entry with the same intensity. Instead, the system is designed to flag entries that warrant closer examination -- the ones that look worth reviewing.

### A Centralized Audit Trail Inside ACE

Every CAPE claim, every adjustment, every recalculation, and every decision is now recorded in one place. CBP has not characterized this as an audit mandate. But it is a system that evaluates claims before money is refunded.

**CAPE is essentially an audit of the original entry with a refund function.**

## The Real Risk: What Happens With Data

The CSV upload starts the entire process. The complexity begins once ACE starts recalculating your entries without IEEPA duties.

When the system strips the IEEPA Chapter 99 codes, it does not just reduce your total. It recalculates the entire entry through ACE's standard validation logic -- the same logic that reviews every commercial entry filed in the United States. That means your HTS classifications, your declared values, your country of origin determinations, and your duty calculations are all exposed to fresh scrutiny.

![IEEPA-attestation-graphic](https://www.jetworldwide.com/hs-fs/hubfs/IEEPA-attestation-graphic.webp?width=471&height=208&name=IEEPA-attestation-graphic.webp)

Importers with clean entries and accurate classifications should move through the process without incident. But those who may have used IEEPA tariff codes to sidestep obligations under other programs -- Section 232 steel and aluminum duties, Section 301 China tariffs, or country of origin requirements -- face real exposure.

Social Media Comment from a licensed customsbroker: "The portal process is relatively straightforward. You submit the required information, and if something needs to be corrected, it is returned for revision and resubmission. That is very different from the idea that you only get one chance and need extensive paid help just to avoid losing the refund."

One trade expert put it bluntly: if CBP catches incorrect tariff classifications where importers were paying IEEPA to avoid 232, 301, or proper country of origin determinations, the consequences extend well beyond a delayed refund.

Each piece of data submitted through CAPE flows into ACE, where it runs against audit criteria that CBP has been building and refining for years. CAPE uses ACE internal tools to flag anomalies and concerns on entries. Newly recalculated entries will undergo the same data reviews.

### Uploading into CAPE, Verify the following data is correct:

* The [country of origin](https://www.jetworldwide.com/blog/understanding-country-of-origin-rules)

* The HTS classification(not just the product HTS but the 99's as well).

* The [declared value](https://www.jetworldwide.com/blog/declared-value-cif-and-valuation-for-international-shipping) is correct (Taking deductions for transportation and insurance?)

* There are no material omissions or false statements

## The Day One Bottleneck

Beyond compliance risk, there is a practical operational concern that is not getting enough attention: System capacity! But the initial reports are encouraging. 

There is no advantage to being first in line if the system is overwhelmed. A measured approach -- ensuring data quality before uploading -- will serve importers far better.

## The Carrier Question: How Millions of FedEx, UPS, and DHL Entries Will Be Managed

There is a massive category of IEEPA-affected entries that is not getting enough attention in CAPE discussions: the millions of shipments where FedEx, UPS, or DHL acted as the Importer of Record.

The IEEPA Refund Process for Express Consignment Shipments (CFR Part 128) are not clearly defined

- Imports cleared via an informal entry (under $2,500): FedEx, UPS and DHL acted Importer of Record
- Imports cleared with a Power of Attorney given to FedEx, UPS and DHL (many such importers are not [registered for ACH](https://www.jetworldwide.com/blog/ieepa-refund-cape#ACH)).

Throughout the IEEPA tariff period -- roughly March 2025 through February 24, 2026 -- these carriers collected and remitted IEEPA duties on behalf of shippers and consumers across millions of transactions. The question of how those duties get returned to the people who actually paid them is layered. This includes how each entry was filed, conditions of carriage, and contractual obligation.

### Three Categories, Three Different Refund Paths

Not all carrier-handled entries are the same. The refund path depends on the filing relationship and entry type:

A

#### Carrier as Customs Broker Only

Where the shipper or consignee was listed as the Importer of Record and the carrier acted only as the customs broker, the refund responsibility falls on the IOR. The IOR (or their broker) files the CAPE Declaration. 

B

#### Carrier as Importer of Record (Formal and Informal Entries)

Where the carrier itself was listed as the IOR on formal or informal entries filed in ACE, the carrier must file the CAPE Declaration and receive the CBP refund. 

C

#### Section 321 and De Minimis Entries Without Entry Summaries

Usually duty free so not affected by IEEPA

### What Each Carrier Has Said

**FedEx** has publicly committed to issuing refunds for IEEPA tariffs paid to shippers and consumers who originally bore those charges. FedEx has also filed its own lawsuit in the Court of International Trade seeking a full refund of all IEEPA duties it paid as IOR.

**DHL** has stated it will continue to engage with relevant authorities for entries where it acted as IOR -- whether formal or informal -- but has not committed to a specific pass-through timeline or mechanism.

**UPS** has focused its public guidance on advising importers to ensure their ACE Portal access and ACH are current. UPS has noted that Non-Resident Importers unable to provide NACHA-compliant US bank details can designate UPS Supply Chain Solutions as the notify party for refund handling.

READ MORE: [FedEx, UPS and DHL Express Courier (CFR Part 128) refunds](https://www.jetworldwide.com/blog/ieepa-fedex-ups-dhl-refunds)

**The legal pressure is real.** Multiple class action lawsuits have already been filed against both FedEx and UPS in federal courts across the country. The customs law is clear: The refunds go to the importer of record. The issue for FedEx, UPS and DHL relate more to contract law.

**Post-suspension low-value entries** (after de minimis was suspended through February 24, 2026): Once the de minimis exemption was removed, shipments that previously cleared duty-free were forced into informal (Type 11) or formal (Type 01) entry processes. IEEPA duties were collected on these entries, and the carriers typically served as IOR or broker. These entries *should* have entry summaries in ACE and *should* be CAPE-eligible -- but the carriers need to file the CAPE Declarations.

**Non-ABI entries with no entry summary lines in ACE:** CBP has explicitly identified this as a category deferred to future CAPE phases. Some entries processed outside standard ACE channels -- including certain postal entries and legacy manifest clearances -- may lack the data structure that CAPE requires. The Court of International Trade has also specifically noted that its refund order does not address de minimis treatment under 19 U.S.C. Section 1321, which is the subject of separate litigation.

### The Pass-Through Problem at Scale

Even where the CAPE mechanics work -- where the carrier files the declaration, CBP processes the refund, and the money flows to the carrier via ACH. Consider the scale of FedEx, UPS, and DHL who processed millions of IEEPA-dutiable shipments. Each shipment was invoiced to an individual recipient or business. Reconciling those invoices, matching refund amounts to individual transactions, and distributing credits or payments across that volume is a significant IT, accounting, and customer service undertaking.

### If a Carrier Collected IEEPA Duties on Your Behalf

✓

#### Preserve All Shipping Invoices and Receipts

Retain every invoice showing IEEPA tariff charges, import duty fees, customs fees, or tariff-related surcharges from FedEx, UPS, or DHL for shipments between March 2025 and February 24, 2026. Look for line items labeled "customs duty," "tariff surcharge," or "IEEPA fee."

✓

#### Determine Your Filing Relationship

Were you listed as the Importer of Record, or was the carrier? If you were the IOR, you (or your broker) need to file the CAPE Declaration. If the carrier was the IOR, the carrier must file and then pass the refund through to you.

✓

#### Contact Your Carrier Directly

Ask your carrier what their specific plan is for filing CAPE Declarations and returning refunds. FedEx has established dedicated support lines for tariff refund inquiries. Get a commitment in writing if possible.

✓

#### Monitor Class Action Developments

Multiple class action lawsuits have been filed against carriers seeking refunds of IEEPA duties and associated processing fees. If you paid significant IEEPA charges through a carrier, you may be a potential class member. Keep records organized in case they are needed.

✓

#### If You Are a Business IOR, Act Independently

Do not wait for a carrier if you were listed as the IOR on formal entries. Confirm your ACE Portal access, verify your ACH enrollment, and prepare your own CAPE Declaration for eligible entries.

### Why This Matters for the Broader CAPE Process

The carrier-as-IOR issue is not a footnote. Express carriers handle a substantial share of all US import entries by volume. When FedEx, UPS, and DHL file CAPE Declarations for entries where they served as IOR, those filings will represent millions of entry numbers flowing into a system already processing claims from 330,000 individual importers. The processing burden -- on CBP, on ACE, and on the carriers themselves -- is enormous.

For Canadian exporters shipping to US customers through express carriers, this has direct implications. If your US buyers received goods through FedEx, UPS, or DHL during the IEEPA period and the carrier was listed as IOR, the refund path runs through the carrier. Your buyers should be in contact with the carrier to understand timing and mechanics.

The bottom line: CAPE was designed around the traditional IOR-broker relationship. The carrier-as-IOR model -- particularly at the scale of millions of parcel and low-value entries -- is a layer of complexity that neither CAPE nor the carriers have fully solved yet.

## Beyond Refunds: The Enforcement Horizon

The compliance community is also watching for longer-term consequences. Several legal experts have noted that the CAPE process could generate referrals for formal audit activity or even enforcement actions.

Refund claims of this magnitude will attract scrutiny. Large-scale recovery efforts tied to a high-profile Supreme Court decision are precisely the kind of activity that draws focused reviews. Companies that proactively validate their import practices and documentation will be far better positioned than those who treat CAPE as a simple administrative exercise.

Some attorneys have raised the possibility that the review process could eventually feed enforcement through mechanisms like the False Claims Act, particularly where refund claims are found to rest on inaccurate underlying data. The key shift in thinking is that refunds trigger scrutiny, not closure. The process does not end when money moves -- it starts there.

As one observer noted, this is CBP's opportunity to demonstrate that its audit capabilities can identify discrepancies efficiently. The agency has been investing in auditors and data analytics for years. CAPE gives them a structured, centralized dataset to work with.

## What Canadian Exporters and US Importers Should Do Now

For businesses shipping goods into the United States -- including Canadian companies managing US import compliance -- the action items are clear:

### Pre-Filing Action Checklist

✓

#### Confirm ACE Portal Access and ACH Enrollment

CBP no longer issues paper refund checks. All refunds are electronic. If your banking information is not on file in ACE, your refund will sit in reject status until it is. As of late March, roughly 78 percent of affected importers had completed ACH enrollment.

✓

#### Audit Your Entries Before You File

Do not submit a CAPE declaration until you have reviewed the underlying data. Verify HTS classifications, country of origin declarations, and duty calculations. If any entries relied on questionable classification strategies, address those issues before they are exposed during recalculation.

✓

#### Separate Phase 1 Eligible Entries from Complex Scenarios

Phase 1 covers most unliquidated entries and entries liquidated within the last 80 days -- approximately 63 percent of all affected entries. Entries involving AD/CVD duties, drawback claims, reconciliation, or final liquidation beyond the 80-day window are excluded and will be addressed in future phases.

✓

#### Coordinate Across Compliance, Finance, and Legal Teams

This is not a task for any single function. The refund has financial planning implications, compliance risk implications, and potential legal exposure. Treating it as a cross-functional project is the only responsible approach.

✓

#### Plan Your Filing Timing

There is no benefit to filing on day one if your data is not clean. A well-prepared submission filed in the second or third week will process more smoothly than a rushed filing that triggers rejection or review flags.

[![Get a shipping quote](https://no-cache.hubspot.com/cta/default/213869/b8064d2c-d3cb-4934-ae43-2dc1f71ab67d.png)](https://cta-redirect.hubspot.com/cta/redirect/213869/b8064d2c-d3cb-4934-ae43-2dc1f71ab67d)

## IEEPA and CAPE Refund FAQs

How do I access IEEPA refunds if I do not have access to the Automated Commercial Environment (ACE)?

Low-volume importing businesses not enrolled in ACE can still apply for an IEEPA refund through their customs broker that submitted the entry on their behalf.

What is the timeline for IEEPA refund requests processed through CAPE?

Based on the tentative CAPE refund timelines, refunds for approved requests are expected within 45 days. However, the timeline is subject to change.

Which IEEPA-related refunds will be given priority?

In Phase 1, only refund requests for unliquidated entries and entries that have liquidated within the past 80 days will be processed. Complex entries -- those flagged for reconciliation, with drawback claims, a protest, and entries with antidumping or countervailing duty orders -- will be processed in a later phase. Some estimates imagine the process stretching out into 2027.

Should a protective protest be filed on all liquidated IEEPA customs entries?

This depends on the age and date of liquidation of the entry. Entries with a protest are -- by definition -- more complex, and this may delay the timing of the refund. However, some recommend this step to protect the refund itself. That decision ultimately rests with each importer.

Will Customs subtract IEEPA refunds against outstanding balances an importer has with CBP?

There is nothing to suggest that IEEPA refunds will be netted out against an outstanding balance. Yet this remains a possibility.

How will customs manage IEEPA refunds for liquidated entries outside the protest period that have not been protested?

There is no clear guidance on how customs will manage liquidated entries that fall outside the protest period but have not been protested. While the U.S. International Court of Trade (CIT) ruled that all entries must be refunded, there is still a lack of clarity as to whether that includes un-protested, liquidated entries.

What is CAPE and how does the four-step process work?

CAPE stands for Consolidated Administration and Processing of Entries. It is a purpose-built system inside the ACE Portal that processes IEEPA tariff refunds through four steps: (1) a Claim Portal for CSV upload of entry numbers, (2) Mass Processing to strip IEEPA Chapter 99 codes and recalculate duties, (3) a Review and Liquidation step where CBP evaluates recalculated entries, and (4) Refund Processing where approved amounts are disbursed electronically through ACH. The critical distinction is that CAPE is a review engine with a refund function -- not a simple payment tool.

## The Bottom Line

CBP deserves credit for building CAPE as quickly and logically as they have. Returning $165 billion or more to 330,000 importers across 53 million entries is an unprecedented operational challenge, and the phased, systematic approach reflects serious institutional effort. Importers need to understand that CAPE is not a refund portal in the way most businesses are imagining it. It is a structured process with a review engine at its core. 

**Those who treat this as a compliance exercise -- with defensible positions, clean data, and coordinated preparation -- will recover their money efficiently. **

![Jet Worldwide delivery van on a city route, representing international logistics and customs brokerage services](https://www.jetworldwide.com/hs-fs/hubfs/jet-van-city-route-2024.webp?width=340&height=221&name=jet-van-city-route-2024.webp)

---

*Jet Worldwide provides international logistics, customs brokerage, and trade compliance services for businesses shipping to and from the United States and Canada. For guidance on cross-border trade strategies, [contact our team](https://www.jetworldwide.com/contact).*

 12 min read  Updated April 16, 2026 Trade Compliance

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[IEEPA tariff refunds](https://www.jetworldwide.com/blog/topic/ieepa-tariff-refunds), [IEEPA post summary correction](https://www.jetworldwide.com/blog/topic/ieepa-post-summary-correction), [IEEPA duty recovery for importers](https://www.jetworldwide.com/blog/topic/ieepa-duty-recovery-for-importers), [IEEPA CAPE](https://www.jetworldwide.com/blog/topic/ieepa-cape)

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    "name" : "Jet Worldwide",
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  "dateModified" : "2026-04-16",
  "datePublished" : "2026-04-16",
  "description" : "CBP launches the CAPE refund system on April 20, 2026. Learn why this is a compliance review engine and not a simple refund portal, and how to prepare your entries before filing.",
  "headline" : "IEEPA Refund Reality Check: Why CAPE Is Not a Simple CSV Upload",
  "image" : "https://213869.fs1.hubspotusercontent-na1.net/hubfs/213869/ieepa_cape_refund_process-jetship-graphic.webp",
  "keywords" : [ "IEEPA refund", "CAPE system", "CBP refund process", "customs tariff refund", "IEEPA tariff recovery", "ACE Portal", "customs compliance", "HTS classification", "trade compliance", "Section 301", "Section 232", "USMCA" ],
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```json
{
  "@context" : "https://schema.org",
  "@type" : "FAQPage",
  "mainEntity" : [ {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "Low-volume importing businesses not enrolled in ACE can still apply for an IEEPA refund through their customs broker that submitted the entry on their behalf."
    },
    "name" : "How do I access IEEPA refunds if I do not have access to the Automated Commercial Environment (ACE)?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "Based on the tentative CAPE refund timelines, refunds for approved requests are expected within 45 days. However, the timeline is subject to change and complex entries may take longer."
    },
    "name" : "What is the timeline for IEEPA refund requests processed through CAPE?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "In Phase 1, only refund requests for unliquidated entries and entries that have liquidated within the past 80 days will be processed. Complex entries involving reconciliation, drawback claims, protests, and entries with antidumping or countervailing duty orders will be handled in a later phase. Some estimates suggest the full process could stretch into 2027."
    },
    "name" : "Which IEEPA-related refunds will be given priority?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "This depends on the age and date of liquidation of the entry. Entries with a protest are more complex by definition, which may delay the refund timing. However, some professionals recommend this step to protect the refund itself. That decision ultimately rests with each importer."
    },
    "name" : "Should a protective protest be filed on all liquidated IEEPA customs entries?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "There is nothing to suggest that IEEPA refunds will be netted out against an outstanding balance, but this remains a possibility."
    },
    "name" : "Will Customs subtract IEEPA refunds against outstanding balances an importer has with CBP?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "There is no clear guidance on how customs will manage liquidated entries that fall outside the protest period but have not been protested. While the U.S. International Court of Trade ruled that all entries must be refunded, there is still a lack of clarity on whether that includes un-protested, liquidated entries."
    },
    "name" : "How will customs manage IEEPA refunds for entries outside the protest period that have not been protested?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "CAPE stands for Consolidated Administration and Processing of Entries. It is a purpose-built system inside the ACE Portal that processes IEEPA tariff refunds. It has four components: a Claim Portal for CSV upload, Mass Processing to strip IEEPA codes and recalculate duties, a Review and Liquidation step, and Refund Processing via ACH. CAPE is a review engine with a refund function attached, not a simple payment tool."
    },
    "name" : "What is CAPE and how does it work?"
  } ]
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```

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  "name" : "How to Prepare for IEEPA Tariff Refunds Through CAPE",
  "step" : [ {
    "@type" : "HowToStep",
    "name" : "Confirm ACE Portal Access and ACH Enrollment",
    "position" : 1,
    "text" : "Ensure your ACE Portal account is active and your ACH banking information is current. CBP no longer issues paper refund checks. If your banking details are not on file, your refund will remain in reject status."
  }, {
    "@type" : "HowToStep",
    "name" : "Audit Your Entries Before Filing",
    "position" : 2,
    "text" : "Review the underlying data for every entry you plan to submit. Verify HTS classifications, country of origin declarations, and duty calculations. Address any questionable classification strategies before they are exposed during CAPE recalculation."
  }, {
    "@type" : "HowToStep",
    "name" : "Separate Phase 1 Eligible Entries from Complex Scenarios",
    "position" : 3,
    "text" : "Identify which entries qualify for Phase 1 processing (unliquidated entries and entries liquidated within the last 80 days). Set aside entries involving AD/CVD duties, drawback claims, reconciliation, or entries outside the 80-day window for future phases."
  }, {
    "@type" : "HowToStep",
    "name" : "Coordinate Across Compliance, Finance, and Legal Teams",
    "position" : 4,
    "text" : "Treat the CAPE filing as a cross-functional project with financial planning, compliance risk, and legal exposure implications."
  }, {
    "@type" : "HowToStep",
    "name" : "Plan Your Filing Timing",
    "position" : 5,
    "text" : "Avoid rushing to file on launch day. A well-prepared submission filed in the second or third week will process more smoothly than a rushed filing that triggers rejection or review flags."
  } ]
}
```

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    "@type" : "Thing",
    "name" : "U.S. Customs and Border Protection",
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  }, {
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    "name" : "Consolidated Administration and Processing of Entries",
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  "citation" : {
    "@type" : "LegalCase",
    "docketNumber" : "1:25-cv-00595-RKE",
    "name" : "Euro-Notions Florida, Inc. v. United States",
    "url" : "https://www.courtlistener.com/docket/72034984/euro-notions-florida-inc-v-united-states/"
  },
  "dateModified" : "2026-05-02",
  "datePublished" : "2026-05-02",
  "description" : "On April 28, 2026, CBP Executive Director Brandon Lord filed a sworn declaration in Euro-Notions Florida v. United States confirming that the CAPE refund tool processed 75,306 declarations and accepted 11.2 million entries for IEEPA duty removal in its first six days.",
  "headline" : "CBP Confirms CAPE Is Working: Inside the April 28 Court Filing on IEEPA Tariff Refunds",
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  "@type" : "FAQPage",
  "mainEntity" : [ {
    "@type" : "Question",
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      "text" : "CAPE — the Consolidated Administration and Processing of Entries — is a new functionality inside CBP's Automated Commercial Environment (ACE) that calculates and issues refunds of additional ad valorem duties imposed under the International Emergency Economic Powers Act (IEEPA). It strips the IEEPA Chapter 99 line from accepted entries and pushes the recalculated entries into the standard liquidation and refund pipeline."
    },
    "name" : "What is CAPE and what does it do?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "CAPE Phase 1 went live at 7:11 a.m. Eastern Time on Monday, April 20, 2026. ACE recorded an approximately 70 percent increase in daily log-ins on launch day compared with its previous record."
    },
    "name" : "When did CAPE Phase 1 launch?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "As of 8:00 p.m. Eastern Time on Sunday, April 26, 2026, CBP had received 75,306 CAPE declarations, of which 47,315 passed file validations. Those validated declarations covered 11,222,927 entries accepted for IEEPA duty removal, with approximately 1,740,000 entries already liquidated and in the refund process."
    },
    "name" : "How many CAPE declarations have been filed so far?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "Only the importer of record (IOR) or the licensed customs broker who filed the original entries on behalf of the IOR may submit a CAPE Declaration through the ACE Secure Data Portal."
    },
    "name" : "Who can file a CAPE Declaration?"
  }, {
    "@type" : "Question",
    "acceptedAnswer" : {
      "@type" : "Answer",
      "text" : "CBP advises that valid IEEPA refunds will generally be issued within 60 to 90 days following acceptance of a CAPE Declaration, unless a compliance concern requires further review. All refunds are paid electronically via ACH."
    },
    "name" : "How long after acceptance are CAPE refunds issued?"
  } ]
}
```

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