Two months ago, I wrote about the Supreme Court’s landmark ruling striking down IEEPA-based tariffs and asked the question, “Are refunds coming?” Now we have the answer, and it comes with a deadline.
On April 20, 2026, U.S. Customs and Border Protection (CBP) officially launched the Consolidated Administration and Processing of Entries (CAPE) portal, the government’s gateway for processing refund claims on IEEPA (International Emergency Economic Powers Act) duties. With an estimated $166 billion in recoverable duties on the line, the clock is now running for businesses that want to recover what they paid.
What is CAPE and How Does It Work?
CAPE lives inside CBP’s existing Automated Commercial Environment (ACE) Secure Data Portal, the same platform importers already use for entry filings. Rather than requiring businesses to file protest after protest on each individual shipment, CAPE consolidates all eligible refund requests into a single submission called a “CAPE Declaration.”
To file, an Importer of Record (IOR), or their licensed customs broker, uploads a comma-separate values (.csv) file listing all entry numbers for which refunds are being requested. CBP then validates the submission, recalculates duties without IEEPA surcharges, and issues refunds electronically via ACH direct deposit.
Per CBP, in most cases, approved refunds are expected to reach businesses within 60-90 days of acceptance. However, claims containing errors may take longer to process. CBP has not officially specified a submission-to-acceptance timeline, but acceptance itself follows two validation rounds (declaration-level and entry-level) that are estimated to take 2-4 weeks after submission.
In addition, CBP has indicated it can take up to an additional 45 days from acceptance to review and liquidate each entry, which precedes the refund. Therefore, a realistic total timeline from submission to direct deposit is roughly 10-24 weeks.
Who Can File a CAPE Declaration?
Only two parties can submit a CAPE Declaration:
- The Importer of Record (IOR) who paid the IEEPA duties, or
- The licensed customs broker who filed the entries on behalf of the IOR
It is important to understand that these are not automatic refunds; CBP will not proactively identify your entries and send you a check or deposit funds into your account. Each business must affirmatively opt-in, assemble its entry data, and file through the CAPE portal. End customers or resellers who faced higher prices due to IEEPA tariff passthroughs are not eligible to file claims.
Phase 1: What Is and Is Not Covered Right Now
CAPE is being deployed in phases, and Phase 1 has important limitations. The initial launch covers only:
- Unliquidated entries: These are shipments where CBP has not yet finalized the duty amount
- Entries within 80 days of liquidation: Recently finalized entries within the reliquidation window.
Estimates suggest Phase 1 covers roughly 63% of total IEEPA duties paid and the remaining 37% of entries (those already liquidated or currently being protested) are excluded from this phase. CBP has indicated that subsequent phases will address more complex scenarios, but no official timeline for official phases has been announced. Therefore, if businesses have entries outside of the Phase 1 parameters, preserving complete documentation now is critical to protecting refund rights when additional guidance is released.
As a reminder, the following tariff categories remain active and are not eligible for refund under CAPE:
- Section 232 duties on steel and aluminum
- Section 301 duties on Chinese goods
- Section 122 surcharge currently in effect at 15%
Practical Steps to Take Right Now
The portal is live, but the burden to act is on each individual business. Based on CBP’s guidance, here is the sequence that matters:
- Verify your ACE Portal access. Confirm that you or your customs broker has an active ACE Secure Data Portal account with importer sub-account access.
- Enroll in ACH. Electronic funds transfer enrollment is a prerequisite for receiving refunds. Without it, even approved claims will be rejected and delayed.
- Compile your entry list. Pull every entry filed between April 5, 2025, and Feb. 24, 2026, on which IEEPA duties were paid. Separate these by liquidation status to identify Phase 1-eligible entries.
- Audit your CBP Form 7501s. Ensure digital copies of all entry summaries are on hand and that tariff classifications are accurate.
- Coordinate with your customs broker early. If your broker is filing on your behalf, get in their queue now. CAPE processing capacity will be under significant pressure in the first weeks of the portal's operation.
- Watch for Phase 2 guidance. If a portion of your duties fall outside Phase 1 coverage, do not discard any documentation. Subscribe to CBP's IEEPA refund email updates to stay current.
Early Feedback on Tariff Refund Portal Issues
In the first few days since the portal’s opening, some businesses have reported technical errors, such as duplicate Tax ID issues, when attempting to access their ACE account. CBP has acknowledged these reports and is actively working to resolve them.
CBP encourages businesses to contact them directly as errors are encountered and document your attempts to file, noting that early technical problems should not cost businesses their right to a refund.
The Bottom Line
The refund opportunity is now real with billions in refunds ready for eligible businesses to collect. Businesses that act quickly will be better positioned to recover funds sooner.
Our team at Mowery & Schoenfeld has been closely tracking the CAPE rollout. If you need help quantifying your potential refund or assembling entry data, please reach out to your Mowery & Schoenfeld advisor.
For background on the Supreme Court ruling that made these refunds possible, see our earlier article: Navigating the Supreme Court's Tariff Ruling: Are Refunds Coming?