U.S. Customs and Border Protection (CBP) has released additional details regarding its upcoming process for issuing refunds of IEEPA tariffs, as directed by the Court of International Trade. CBP is developing a new capability within ACE, known as the Consolidated Administration and Processing of Entries (CAPE), which is currently 60–85% complete across its four components.
Phase 1 will focus on a defined subset of entries—primarily those that are unliquidated or still within the 90-day voluntary reliquidation window—covering approximately 63% of impacted entries. While certain entries (including those with suspended or extended liquidation, warehouse entries, and AD/CVD-affected entries) may be submitted, refunds for these will be issued through the standard liquidation process rather than through CAPE.
At this stage, CAPE will not support certain entry types, including reconciliation entries, drawback claims, protested entries, and entries not filed in ACE.
CBP expects to process eligible submissions within required regulatory timeframes, with review periods of up to 45 days.
Future phases will expand CAPE’s capabilities to include additional entry types, enhanced validations, financial reporting tools, and more complex processing scenarios.
Importers are also reminded that electronic refund capability is required to receive IEEPA tariff refunds. CBP has indicated that some importers have not yet completed this setup and should do so promptly to avoid delays. We recommend importers start with a current CBP 5106 to ensure the correct email address is associated with the importer account. Once processed and synchronized by CBP - typically within 24 hours- the remaining setup using the Importer Form can be completed quickly and efficiently. Please connect with your Customer Service Representative to begin the process.